The Pharmaceutical Society of Uganda (PSU) has urged the Ministry of Health to align the leadership and administration of the Pharmacy Board with its interpretation of the Pharmacy and Drugs Act, arguing that the Commissioner for Pharmaceuticals and Natural Medicines should also serve as the Chief Pharmacist and Registrar of the Pharmacy Board.
In a resolution adopted during its 61st emergency meeting held on October 13, 2026, at Pharmacy House in Kampala, the PSU Council said the separation of the offices of Commissioner for Pharmaceuticals and Natural Medicines and Registrar of the Pharmacy Board had raised concerns about compliance with the law governing the pharmacy profession.
The council said its position was informed by its review of Sections 2 and 4 of the Pharmacy and Drugs Act, Cap. 309, the Ministry of Health's established administrative structure and concerns raised by members of the professional body.
According to the society, the law provides for the Chief Pharmacist to serve as a member of the Pharmacy Board and to perform the functions of Registrar and Secretary of the board.
The council argues that the Ministry of Health's current structure does not expressly provide for a separate position of Chief Pharmacist, just as it does not expressly provide for a Chief Medical Officer.
It maintains that the Commissioner for Pharmaceuticals and Natural Medicines, as head of the Pharmacy Department at the ministry, is the equivalent of the Chief Pharmacist under the existing administrative structure.
In its guidance, the council reaffirmed its interpretation that the commissioner should, by virtue of that office, exercise the statutory responsibilities of Registrar and Secretary of the Pharmacy Board.
“Council reaffirms its interpretation that under the Pharmacy and Drugs Act, the expectation is that the Head of Pharmacy Department, Ministry of Health (Commissioner Pharmaceuticals and Natural Medicines), is by virtue of that office the Chief Pharmacist and shall therefore exercise the additional statutory role of Registrar and Secretary, Pharmacy Board,” the resolution says.
The society has called on the Ministry of Health to address what it describes as an anomaly in the appointment of an acting registrar while the office of Commissioner for Pharmaceuticals and Natural Medicines was substantively occupied.
The council said the registration of pharmacists is a statutory responsibility that must be exercised by the office bearer prescribed by law, rather than treated as a routine administrative assignment.
It warned that failure to establish clear compliance with the legal provisions governing the Pharmacy Board could expose registration decisions to future legal challenges.
“The registration of pharmacists is a statutory function, not merely an administrative assignment, and must be performed by the office bearer as expressly provided by law to avoid future litigations concerning the legality of registration of members and the proper composition of the Board,” Dr.Stephen Lutoti , the secretary for the Pharmaceutical Society of Uganda said.
The society's position places emphasis on the relationship between the statutory responsibilities of the Pharmacy Board and the administrative structure of the Ministry of Health.
The council further cited the position of the Director General of Health Services, who serves as chairperson of the Pharmacy Board, as an indication of the statutory hierarchy it believes should guide the appointment of the registrar.
According to the resolution, the Director General of Health Services occupies a role equivalent to that of the Chief Medical Officer, reinforcing the council's argument that the corresponding pharmacy leadership responsibilities should be clearly recognised within the ministry's structure.
The PSU Council resolved that the Ministry of Health should be guided to correct what it considers an inconsistency arising from the appointment of a person other than the Commissioner for Pharmaceuticals and Natural Medicines as acting registrar while the commissioner's office was substantively occupied.
The council said restoring what it considers the correct statutory arrangement would help ensure that the Pharmacy Board operates in accordance with the Pharmacy and Drugs Act.
“Council resolved that the Ministry of Health be guided so that the anomaly where a person other than the Commissioner Pharmaceuticals and Natural Medicines, who is the Chief Pharmacist, was appointed as an acting registrar while the office of the commissioner was substantively occupied be corrected to restore compliance with the PDA,” the resolution states.
The council also acknowledged the work of pharmacists who have previously served in an acting capacity as registrar, emphasising that its position was intended to address the institutional arrangement rather than disregard the contributions of individual members.
It recognised the services of members who had supported the ministry in administrative roles while serving as acting registrar in previous years.
The council extended the same appreciation to the current acting registrar, who, according to the resolution, has served in that capacity for the past three years.
The society said its guidance should not be interpreted as dismissing the contributions of those who have performed the role but as an effort to clarify the statutory responsibilities attached to the office.
The council directed that its resolution be communicated to the Minister of Health, the Permanent Secretary, the Director General of Health Services, the Pharmacy Board and other relevant government ministries, departments and agencies, as well as members of the Pharmaceutical Society of Uganda.
The development comes amid the society's concerns about the separation of the commissioner and registrar positions and the implications this could have for the constitution of the Pharmacy Board and the legal validity of pharmacist registration decisions.