ABPI Code Clause Heatmap

Which clauses are breached most โ€” across 1,930 PMCPA cases since 2010

Clause-level data recorded for 1,670 cases  ยท  Last updated: 23 Jun 2026

About this data: Based on 1,670 cases where clause-level data is recorded (out of 1,752 total cases in the training database). Not all PMCPA rulings include a granular clause breakdown โ€” clause data is added as cases are enriched over time. The heatmap reflects the clauses appearing most frequently in recorded breaches.
Showing 1670 cases with clause data

Clause Breach Heatmap

Click any clause to expand sub-clauses. Darker = higher breach frequency.

Fewer
More
2 21
Bringing Discredit
3 33
Licence & Regulations
▼ sub-clauses
4 84
Misleading Claims
▼ sub-clauses
5 1
Substantiation of Claims
▼ sub-clauses
6 1
Comparisons
▼ sub-clauses
7 51
Disparagement
▼ sub-clauses
8 3
Testimonials
▼ sub-clauses
9 181
High Standards
▼ sub-clauses
10 3
Certification
▼ sub-clauses
11 9
Reprints & Digital Content
▼ sub-clauses
12 6
Scientific Service / MSL
▼ sub-clauses
13
Samples
No data
14 9
Meetings & Hospitality
▼ sub-clauses
15 13
Educational Items
▼ sub-clauses
16
Market Research
No data
17 7
Patient Organisations
▼ sub-clauses
18 6
Non-interventional Studies
▼ sub-clauses
19 5
Clinical Trials
▼ sub-clauses
20 5
Named Patient Supply
▼ sub-clauses
21 1
Transfers of Value
▼ sub-clauses
22 8
Interactions with HCPs
▼ sub-clauses
23 2
Advertising to Public
▼ sub-clauses
24 2
Online & Digital Activities
▼ sub-clauses
25 1
Representative Conduct
26 23
Complaint Procedures
▼ sub-clauses
27 10
Supplementary Information
▼ sub-clauses

Top 10 Most-Breached Clauses

Ranked by number of recorded breaches in the filtered dataset. % column = share of all recorded breach mentions.

# Clause Description Breaches % of Total
1
Clause 9
High Standards
The general requirement to maintain high standards โ€” the fundamental requirement of the ABPI Code.
181 37.3%
2
Clause 4
Misleading Claims
Promotion that is misleading, deceptive or does not accurately represent the medicine being promoted.
84 17.3%
3
Clause 7
Disparagement
Disparagement of other companies, products or their promotional materials.
51 10.5%
4
Clause 3
Licence & Regulations
Promotion of medicines outside the terms of their marketing authorisation or in breach of applicable legislation.
33 6.8%
5
Clause 26
Complaint Procedures
Failure to comply with undertakings given to PMCPA or to respond adequately to PMCPA requests.
23 4.7%
6
Clause 2
Bringing Discredit
Activities or materials that bring discredit to, or reduce confidence in, the pharmaceutical industry.
21 4.3%
7
Clause 15
Educational Items
Educational items, exhibitions, and sponsorship of educational events.
13 2.7%
8
Clause 27
Supplementary Information
Supplementary information and schedules to the Code.
10 2.1%
9
Clause 14
Meetings & Hospitality
Meetings sponsored by companies and hospitality provided to health professionals.
9 1.9%
10
Clause 11
Reprints & Digital Content
Reprints of journal articles and digital content used in promotion.
9 1.9%
ℹ Each "breach" = one clause mentioned in a case ruling. A single case may breach multiple clauses. Total breach mentions in filtered view: 485

PMCPA Case Volume by Year

Total cases vs confirmed breaches (upheld/partially upheld), 2015โ€“present.

How to read this: Light blue bars = all PMCPA cases that year. Dark blue bars = confirmed breach findings. The orange line overlays the number of clause-level breaches recorded โ€” year-by-year density shows where the Code is scrutinised most.

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