The spread is enormous
There is no European position on pharmacy ownership. There are roughly five positions, and which one a country holds determines the entire shape of a business there.
Fully open: Sweden, Norway, Netherlands, Switzerland, Ireland, United Kingdom. A company, including a foreign one with no pharmacist shareholder, can hold the licence. What the law requires instead is a named, qualified, personally accountable pharmacist in the operation.
Open through a responsible pharmacist: Czechia (§16 of zákon 372/2011 Sb., a legal entity holds the licence and appoints an odborný zástupce), Slovakia (§3 ods. 5 of zákon 362/2011 Z.z., the same construction with an odborný zástupca), Lithuania (no pharmacist-ownership requirement in the Farmacijos įstatymas), Croatia (no ownership threshold in the current Zakon o ljekarništvu, though county concession planning constrains where and how many). Functionally this is the same as fully open, and it is where Dr.Max, BENU and Pilulka operate.
Corporate-permitted with limits: Italy (capital companies since 2017, but a pharmacist must direct and no entity may exceed 20% of a region), Portugal (companies may own up to four), Belgium (non-pharmacists may own with a pharmacist-titulaire managing), Malta (the statute disqualifies only prescribers, but entry is rationed at one pharmacy per 2,500 inhabitants and one per owner per locality), Bulgaria (any EU-registered trader, with a hard cap of four), Romania (no ownership rule and no cap at all, rationed instead by urban population ratios of one per 3,000 to 4,000), Greece (investors up to 67% since May 2026, down from 99.99%).
Pharmacist-majority: Estonia (at least 50% since the 2020 apteegireform, and since 2021 subject to a substance-over-form control test), Hungary (above 50% under Act XCVIII of 2006, with the operating right personal to the pharmacist), and Latvia, where the rule is softer than it reads: article 36(2) of the Farmācijas likums is satisfied by a pharmacist holding half the shares or by pharmacists making up half the board, so a group can comply with no pharmacist equity at all.
Closed: Germany (Fremdbesitzverbot, four branches max), France (art. R5125-19, absolute), Spain, Denmark, Finland, Austria, Poland. Three more are closed for reasons that have nothing to do with guild rules and are worth separating out. Slovenia treats pharmacy as a municipal public service delivered through public institutes, with private provision only by personal concession. Cyprus caps ownership at literally one pharmacy per person, so chain pharmacy is prohibited outright and its 615 pharmacies imply 615 owners. Luxembourg is the strictest of all: a pharmacy is a public service held under a personal concession that extinguishes when the holder turns seventy or dies, provisions that cannot coherently apply to a company.
What "open" actually costs you
In every open market the licence is separated from the liability. The Netherlands requires a gevestigd apotheker registered with IGJ and personally responsible 24/7. The UK requires a superintendent pharmacist who is a genuinely empowered senior decision-maker, and the GPhC has suspended a pharmacist for letting "commercial convenience override patient safety", which tells you exactly how that requirement bites. Sweden requires a läkemedelsansvarig. Ireland requires a superintendent with three years post-registration, though notably only one per corporate group.
So the practical constraint in open markets is not legal, it is human: finding a senior pharmacist willing to attach their personal registration to a high-volume, high-scrutiny GLP-1 operation. Budget for that being the long pole.
Where the rules moved in 2025–26
Germany: the ApoVWG passed the Bundestag on 22 May 2026 and deliberately left the Fremdbesitzverbot and four-branch cap untouched. Treat it as settled, not pending.
Greece: went the other way, tightening from a 99.99% investor ceiling to a 33% pharmacist minimum in May 2026, explicitly to deter private equity.
Poland: the 2023 "Apteka dla Aptekarza 2.0" amendment added a four-pharmacy anti-concentration cap; a Constitutional Tribunal referral is unresolved.
Croatia and Lithuania: an earlier version of this page listed both as unresolved. Both are now resolved, and in the same direction. In Croatia the ownership threshold routinely attributed to article 38 of the Zakon o ljekarništvu does not exist; article 38 concerns Chamber financing, and the act contains no ownership cap. In Lithuania the 1 July 2023 reform that closed 34 pharmacies imposed a pharmacist physical-presence requirement, not an ownership restriction. Both belong in the open group.
Estonia: the formal rule has not moved, but the 2021 Riigikohus rulings did. Regulators are directed to assess actual control rather than the shareholder register, which specifically targets nominee structures where a wholesaler or chain retains commercial control through supply and management agreements.
Open on this topic
Sources
Countries where this bites: Bulgaria, Cyprus, Czechia, Germany, Estonia, France, Greece, Croatia, Hungary, Ireland, Italy, Lithuania, Luxembourg, Latvia, Malta, Netherlands, Portugal, Romania, Sweden, Slovenia, Slovakia.