Pfizer: Covid-19 vaccine Phase 3 efficacy tweets ruled promotional pre-authorisation and in breach of undertaking (AUTH/3888/4/24)

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Key facts

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Case	AUTH/3888/4/24
Company	Pfizer Limited
Complainant	Member of the public (taken up by the Chief Executive)
Channel	Twitter (now X) – Pfizer UK account; senior employee retweet; linked Pfizer press release; linked BioNTech content via @BioNTech_Group
Date of material	19 November 2020
Issue	Phase 3 Covid-19 vaccine study results communicated on public social media; relative efficacy presentation; linked content treated as part of the post; alleged and confirmed undertaking breach
Applicable Code year(s)	2019 Code (Tweets); 2021 Code (undertaking breach)
Breach clauses	2019: Clause 2; Clause 3.1; Clause 7.2; Clause 9.1. 2021: Clause 3.3
No breach clauses	2019: Clause 7.2; Clause 7.9; Clause 29
Sanctions	Undertaking received; Advertisement
Complaint received	15 April 2024
Case completed	14 April 2025
Appeal	No appeal

Reviewed by Dr Anzal Qurbain (FFPM) — ABPI Final Signatory

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A member of the public complained about a Pfizer UK Twitter (now X) thread dated 19 November 2020 about Phase 3 results for Pfizer’s Covid-19 vaccine candidate, and a retweet by a senior Pfizer employee adding “What a day!”.
The thread stated the study met all primary efficacy endpoints and included “95% efficacy”, plus “To date, no serious safety concerns…”.
The Pfizer tweet tagged @BioNTech_Group; the Panel treated the BioNTech tweet visible via that tag as linked content and therefore part of the Pfizer activity for this case.
The Pfizer tweet linked to a press release on Pfizer’s website; the Panel also treated the press release as linked content and part of the activity.
Allegations included: promotion of an unlicensed medicine, misleading efficacy claims (relative vs absolute), inadequate safety/adverse reaction information, failure to maintain high standards, bringing discredit on the industry, and breach of undertakings from prior cases.
The Panel considered the “Tweets” collectively as: the Pfizer thread + linked BioNTech tweet content + linked Pfizer press release + the senior employee retweet.

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Breach of Clause 2 (2019 Code).
Breach of Clause 3.1 (2019 Code).
Breach of Clause 7.2 (2019 Code) (misleading claim re efficacy presentation).
Breach of Clause 9.1 (2019 Code).
No breach of Clause 7.2 (2019 Code) (separate allegation about misleading/safety-related claims not established on balance of probabilities).
No breach of Clause 7.9 (2019 Code).
No breach of Clause 29 (2019 Code).
Breach of Clause 3.3 (2021 Code) (failing to comply with an undertaking from AUTH/3741/2/23).

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