Halting the decline in the number of pharmacies, improving access to medicines, increasing competitiveness—and thus lowering drug prices and raising the quality of services—as well as restoring basic rights to entrepreneurs operating in the pharmacy market all require a comprehensive reform of the pharmaceutical sector in Poland. The current state of the market and proposed changes, based on the deregulation of the Italian system, are presented by the Institute of Public Finance (IFP) in its newly published report: “Pharmacy for Pharmacists. The Effects of Pharmacy Market Regulation in Poland.”
The report “Pharmacy for Pharmacists. The Effects of Pharmacy Market Regulation in Poland”, which explores the potential consequences of deregulating the pharmacy market, was commissioned by the Association of Pharmacy Employers PharmaNET and the Lewiatan Confederation.
The Decline of Pharmacies in Poland and Reduced Medicine Security
Currently, Poland has over 11,100 community pharmacies and around 1,100 pharmacy outlets. There are 30 pharmacies per 100,000 inhabitants—less than the EU average of 33.2, three times fewer than in Greece (with the highest rate of 100.8), and more than three times more than in Denmark (the lowest rate in Europe).
In the report, the Institute of Public Finance analyzes changes in the pharmacy market from 2002 to 2024. As a result of the regulations introduced in 2017 and 2023—known as “Pharmacy for Pharmacists” (Polish acronym: AdA)—the number of active pharmacies in Poland has declined, leading to reduced access to medicines. AdA has weakened medicine security without improving the situation of small pharmacy operators. “It is an example of unnecessary regulation that disrupted the normal functioning of the market without delivering any (expected) positive outcomes,” the report states.
Following the introduction of AdA in 2017, the number of pharmacies and pharmacy outlets began to drop:
“Instead of improving access to medicines, ‘Pharmacy for Pharmacists’ is turning Poland into a regulatory museum. The numbers don’t lie—over eight years, the number of municipalities without a pharmacy rose to over 500, and three million Poles now have to travel to neighboring towns to fill prescriptions. It’s high time to send this law into legislative retirement—for the sake of patients,” says Dr. Sławomir Dudek.
“It’s just a matter of connecting the dots and referring to basic economics textbooks. It’s economic common sense: as a business (e.g., a pharmacy chain) grows, average costs decline, and it becomes profitable to expand into less populated areas. This mechanism works in many markets. Without the AdA restrictions, pharmacies could have developed in regions currently lacking access to medicines. I don’t understand how anyone can fail to see this,” he adds.
Deregulating the Pharmacy Market – Possible Scenarios
In light of the current situation, IFP analyzes potential reform scenarios focused on repealing most of the ownership restrictions introduced by the 2017 and 2023 laws—while retaining the current geographical and demographic limits, as was done in Italy. Several thresholds for permissible market concentration were considered—again, inspired by the Italian model, where a single owner can control up to 20% of pharmacies in a province.
According to the analysis, over a 15-year horizon:
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At a 10% concentration threshold:
The number of pharmacies in Poland would increase by 279, market chain coverage would rise from 52% to 63%, and there would be 248 pharmacy networks. -
At a 20% threshold:
The number of pharmacies would increase by 661, chain coverage would reach 72%, with 256 networks. -
At a 30% threshold:
The number of pharmacies would rise by 1,508, chain coverage would grow to 81%, and 265 networks would be operating.
“Even in the most liberal scenario—where we assume the pharmacy market operates under general competition rules similar to other markets—the level of concentration would not increase significantly. While chain coverage would rise to 90%, there would still be 276 companies operating. The total number of pharmacies in Poland would increase by more than 2,000,” says Dr. Konrad Walczyk, head of scientific projects at the Institute of Public Finance and co-author of the report.
“In the scenario where current legal restrictions are maintained, the number of pharmacies would drop by around 750 over the next 15 years—nearly 7%—and chain coverage would increase only from 52% to 62%,” he adds.
Lessons from the Italian Reform
Attorney Marcin Tomasik, partner at Tomasik Jaworski law firm, notes that the reason for Italy’s pharmacy reform before 2017 was the declining number of pharmacy outlets and limited access to medicines and pharmaceutical services. As a result of the reform, the decline was reversed—some provinces even saw growth. Market liberalization and capital inflow, while maintaining geographical and demographic restrictions, increased the value of pharmacy businesses.
Marek Górski, President of the Lewiatan Confederation, emphasizes that the “Pharmacy for Pharmacists” regulation violated the rights of entrepreneurs who had been building their businesses for decades—leading to their practical expropriation:
“This situation limits economic freedom and hampers the development of the pharmacy sector, which is key to public health and patient rights. That’s why we are now presenting specific solutions based on nearly 10 years of Italian reform experience and supported by IFP’s scientific analysis. These reforms put patients’ interests and rights at the center, without unduly restricting economic freedom,” Górski states.
“The reform assumptions we propose are modern, proven in practice, and supported by robust economic analysis. These are comprehensive solutions that address the deep-rooted problems of the pharmacy market in a constructive, forward-looking way—they take nothing away, they don’t limit entrepreneurial energy, and most importantly, they place the patient and their needs at the heart of the reform,” argues Marcin Piskorski, President of PharmaNET.
The authors of the Institute of Public Finance’s report “Pharmacy for Pharmacists. The Effects of Pharmacy Market Regulation in Poland” are Dr. hab. Michał Bernardelli and Dr. Konrad Walczyk.
