Pharma on the socials — the company account, the employee, and the comment thread.

In June 2026 the Australian trade press carried a story from the United Kingdom under the headline trouble over LinkedIn likes… again: eighteen employees of one company, four of them senior managers, had interacted with a third party's post calling the company's cancer medicine "groundbreaking", and the UK code body found eight breaches. It was the third such ruling against the same company and one of a run against others, and every one turned on the same fact — a like, a share or a comment is publication to the employee's network, and the network is the public. Australia has not had its case yet. But the rules it would be judged under are all published, and this guide is those rules: the Act and the Code, the April 2025 Social Media Guidance, and the dozen Help Desk notes that say, before any ruling has had to, what a company account may post, who may see it, what an employee's thumb does, and whose comment thread it is.

Two regimes, one rule

The first regime is the law. Advertising prescription medicines to the general public is prohibited by the Therapeutic Goods Act, and the Code refers to that prohibition rather than restating it § 2.3(a). A social media post is public unless something makes it not — and for a company post about a prescription product, the TGA's view, recorded by Medicines Australia, is that the commercial interest makes it more likely to be read as promotion, not less.

The second is the Code, which is short on the subject because it is "systems neutral": "All activities that utilise any social media platform will be considered in the same way as more traditional media activities" § 10.2. The Glossary defines social media as "the various online platforms and activities that engage users to participate in, comment on and create digital content, and to allow them to interact, share information and network with others, including peer-to-peer conversations" § Glossary — which is to say, the comment thread is in the definition. Then six clauses:

• "Content that can be viewed by the general public should not advertise or include promotional claims for a prescription product" § 10.2(a).
• "Content that includes promotional claims for a prescription product must be restricted to a verified healthcare professional audience" § 10.2(b).
• "Companies are responsible for all content on Company-initiated and/or controlled social media sites and activities" § 10.2(c).
• "Content that does not conform to community standards of ethics and good taste, or which relates to unapproved products or indications, should be promptly removed" § 10.2(d).
• "It is appropriate for Companies to create content that enables its employees to appropriately engage in Company social media campaigns" § 10.2(e).
• "Companies should have policies and procedures which describe the roles and responsibility of its employees and contractors when interacting in the social media space" § 10.2(f).

Over both sits the Help Desk's plainest sentence on the subject (#99, November 2025), written after the TGA published its own social media advertising guidance: there is no absolute safe zone, even when the Code's requirements are met. The § 10.1 inclusions are "designed to lift" a communication toward non-promotional balance; they are a framework, not a guarantee, and a post can satisfy every one and still be promotional on its tone and intent.

The company account

What a company account may post to the public falls into three lanes, each with its own clause.

Disease awareness. Educational information for the public "may include descriptions of the therapeutic category including classes but does not include any reference to a specific prescription product" § 12.2(a); it is "comprehensive, balanced and fair" and does not "unduly emphasise particular options or the need to seek treatment" § 12.2(b); its emphasis is "on the condition and its recognition rather than on the treatment options" § 12.2(c); and its tone "must not be presented in a way that unnecessarily causes alarm or misunderstanding in the community nor stimulate the demand for prescription of a particular product" § 12.2(d). The Help Desk's 2026 note on immunisation-week content (#107) shows the lane's edge: population-level vaccination messaging sits outside the disease-awareness model, and the thing to avoid is an individualised call to action that shifts from advocacy to a treatment decision.

The product-specific statement. A registration, a new indication, a PBS listing or a change to public funding is an occasion on which the company may name the product to the public § 10.1(b) — once per circumstance, as "a single, coordinated release across multiple channels such as consumer media, patient organisations and via companies' digital channels" § 10.1(c). On social media the seven inclusions of § 10.1(e) apply in full — brand, Australian Approved Name, the relevant approved indications, therapeutic class, funding status, a summary of the side-effect profile and warnings, and a link to the CMI — and so do the prohibitions of § 10.1(g): no promotional claims, no comparisons, no promotional quotes from experts or patients, no pack shot, no reference to an access programme. The Help Desk's Edition 20 note on product-specific social media (#85) makes the timing explicit: everything posted or re-shared from 30 March 2025 must meet § 10.1(e), and its worked examples cover the registration post on LinkedIn, the PBS announcement, and the PBAC call on Facebook and on X.

Once has a consequence the Guidance spells out: re-posting, sharing or liking the statement after its release — "particularly on social media" — may be perceived as promotion. So may paid amplification that keeps it in feeds longer than a release would last (#7 calls a continuous-boost campaign unlikely to be non-promotional). A § 10.1 statement goes out once, on the day, and is left alone.

Stakeholder communication. Calling for public comment on a PBAC submission is legitimate stakeholder communication under § 10, and the Help Desk (#41) permits it on X or Facebook with one rule of drafting: name the product or the therapy area, not both, and link to the PBAC agenda page — coupling the two reads as promotion. The Guidance adds a rule of configuration: on a PBAC post, enabling comments invites the public to write the product's benefits under it, and disabling them mitigates that.

Two clauses apply to every post in every lane. Identification: the post carries the company's name and Australian office city or town § OP 10 — satisfied by the page's profile where the post cannot be separated from it, but embedded in the post or the graphic where it can be shared away (#42). And the public landing page of an HCP portal is public: a brand name alone is acceptable there, statements already in the CMI may be repeated if not curated promotionally, and the Help Desk's advice is to keep it to a teaser (#31, #26).

To healthcare professionals

Promotional content has one lawful audience on social media, and it is a verified one § 10.2(b). The Code's requirement that material for professionals be "only able to be viewed or accessed by healthcare professionals" § 2(a), with "a mechanism such as password protection for system entry" online § 2.2(a), applies to a closed group or a gated feed exactly as it does to a website. The Help Desk's line (#48) is the one most affiliates have to hear twice: a LinkedIn job title is not verification. It needs cross-checking against the company's own database or a credential check — AHPRA — before promotional content is served. Non-promotional content, a PBS listing announcement for instance, may be boosted to a wider audience with paid spend; promotional content may not.

The employee

The Code puts two obligations on the company for its people: content that lets them "appropriately engage in Company social media campaigns" § 10.2(e), and "policies and procedures which describe the roles and responsibility of its employees and contractors" § 10.2(f) — under a Principle that reaches "anyone acting on behalf of a Company" § OP 4. The Guidance draws the consequence: a company may be accountable for the posts of employees, contractors and third-party staff, including their personal activity, where the post appears to represent the company.

Liking is not passive. The Help Desk's note on liking and sharing (#55) names three effects of a like: it pings the author, it plugs the post into colleagues' feeds through the algorithm, and it profiles — it appears on the employee's own activity. An employee liking inappropriate content can be a company activity. The note cites the UK's code body as having heard numerous complaints on exactly this, and the record since bears it out: a UK employee found in breach for posting about studies of a company medicine without disclosing affiliation (2023); another company's employee for liking two posts about a product's approval; and the June 2026 case, eighteen staff interacting with a third party's award post, eight breaches, with the panel noting "there could be no doubt" that employees disseminating the post promoted the medicine. Those rulings are under the UK code, not this one — but every element in them is in § 10.2, § OP 4 and the Guidance, and the Help Desk cites them as the warning.

Cross-border is the recurring shape. A global affiliate posts about an unregistered product or trial data from another market; an Australian employee likes it. The Guidance names this as possible cross-border promotion, and the Help Desk's example is a UK employee liking a US post. The Australian entity is not responsible for the global post — until an Australian employee engages with it, it targets an Australian audience, or it is posted on the entity's behalf, at which point responsibility shifts and the content should identify itself as Australian company activity § OP 10.

Profiles and history. The Guidance asks that profile information — job titles, listed publications — not give easy access to product-benefit content, and that old content be reviewed, because it remains accessible. Human error does not absolve the company.

The card below is the employee's half of the § 10.2(f) policy — short enough to be read, specific enough to be followed.

Before you like, share or comment — [Company] Australia

Your name is linked to ours. A like, a share, a comment or a repost is publication to your network, and your network is the public. Before you touch a post that mentions a prescription medicine — ours, a competitor's, or one not registered in Australia — ask five questions.

1. Is it about a medicine? A product name, a molecule, a trial result, an approval, a listing, an award for a product. If yes, keep reading. If it is a company milestone with no product — a new office, a hire, a community program — engage freely.

2. Who posted it? Our Australian company account, on a § 10.1 statement: do not like, share or repost it — the statement is issued once and left alone. A global affiliate: do not engage with anything about a product or use not registered in Australia; it becomes Australian activity when you do. A third party — a society, a journalist, an award, a customer: do not engage if the post makes a claim about a product's benefits, however true.

3. Would a patient see it? On LinkedIn, X, Instagram or Facebook, yes. There is no professional-only setting on a personal account.

4. Are you disclosing? If you post or comment about a medicine in any professional capacity, say who you work for. Never post or comment on a product's benefits, safety or comparison with another product, and never respond to a question about an unapproved use — refer it to Medical.

5. Has someone described a side effect? In a comment, a message, a mention. Report it to [pharmacovigilance contact] within one working day, even if it is not our product.

If in doubt, do not engage, and ask [Compliance / Medical contact]. Removing a like later does not undo it.

The comment thread

The company is "responsible for all content on Company-initiated and/or controlled social media sites and activities" § 10.2(c) — and the TGA's social media advertising guidance says the same thing in its own terms: the owner of a page is responsible for it, including third-party comments, and it recommends an acceptable-use policy that warns commenters that non-compliant content will be removed. Three duties follow.

Remove. Content "which relates to unapproved products or indications" and content below "community standards of ethics and good taste" is "promptly removed" § 10.2(d). A patient comment praising the product's effect under a disease-awareness post is a promotional claim on the company's page; a comment naming an off-label use is off-label content on the company's page.

Monitor for adverse events. The Guidance is explicit that the pharmacovigilance obligations a sponsor owes the TGA apply to social media: to comments on company posts, to mentions, and to posts that company-controlled accounts engage with. A comment thread is a pharmacovigilance channel whether or not the company treats it as one.

Decide whether to respond. The Code permits an educative, non-promotional response to a journalist or editor where an article is factually wrong § 10.1(i). For misinformation in a thread the Guidance is more cautious: selectively correcting some inaccuracies invites scrutiny, responding amplifies, and the safer set is to assess how prevalent the misinformation is, use official references — the CMI, the PI — stay neutral, report content that breaches the platform's rules, and remove misinformation from comments on the company's own posts.

And one decision to make before posting: whether to have a thread at all. Where the subject invites the public to write about a product's benefits — a PBAC call, a listing statement — disabling comments is the Guidance's own suggestion.

Influencers and testimonials

The Code has no section on influencers; the Help Desk (#78) and the Guidance treat them as any other third-party engagement, and the TGA supplies the hard edge. Under the therapeutic goods advertising rules a person paid in any way for a testimonial or endorsement is engaged in marketing the goods — social media influencers, bloggers and brand ambassadors included — and for a prescription medicine there is no lawful advertising to the public at all. An influencer post about a prescription product is an advertisement for it. The lane that exists is disease awareness, under § 12.2, with no product named.

Within that lane the Guidance's list is the engagement contract: a rationale for using an influencer at all; due diligence on their past posts, engagement and alignment with the company's values; verification of who they are; fair market value § 5.1(b); a briefing on messaging, hashtags and whether comments are on; content approval through the company's own review process; ongoing monitoring of posts and comments, adverse events included; and a transparency disclosure on the post — the Guidance's example is "The author of this post has received financial support from Company X" § OP 2. If the influencer is a practising healthcare professional, the fee is a transfer of value and is reported § 14.1.

Hashtags, tags, links and trials

Small mechanics with the same test. A hashtag with a history of misuse is evaluated before it is used; a link must not lead to promotional or inappropriate content, and a company site linking out carries the Code's leaving-site statement § 2.2(c); a tagged account must not lead viewers to prescription-product promotion. Clinical-trial recruitment on social media is permitted provided it does not advertise the therapeutic good: no product name in the recruitment post, no language or imagery suggesting the trial is "the innovation they need", and a preference for independent registry links over the company's own site.

The policy

§ 10.2(f) requires it; the Guidance's five-step framework is its spine — assess the objective, consider the audience, define the content, consider the channel's step-up (comments, sharing, suggested content), and fix ownership and control with a compliance signatory — and the TGA asks for the page-facing half. Together they make two documents: the employee's card above, and this.

Acceptable use — [Company] Australia social media accounts

Purpose. [Company]'s Australian accounts share information about the company, about health conditions, and — on the occasions the Medicines Australia Code of Conduct permits — about the registration and public funding of our medicines. They do not advertise prescription medicines, which Australian law prohibits.

What we post. Company news; disease-awareness information that names no prescription product § 12.2; product-specific statements on registration, new indications and public funding, each issued once and carrying the information the Code requires § 10.1(e); calls for public comment on PBAC submissions. Every post is approved by [role] and identifies [Company] and its Australian office § OP 10.

What we don't. Claims about a medicine's benefits, safety or superiority; comparisons; pack shots; promotional quotes from experts or patients; references to unregistered products or unapproved uses; re-posts or boosts of a product statement after its release.

Comments. We welcome comments and read every one. We remove, without notice, comments that describe the benefits or effects of a prescription medicine, that refer to a use not approved in Australia, that give or seek medical advice, that are abusive, or that breach the platform's rules § 10.2(d). We do not answer medical questions here: please speak to your doctor or pharmacist, or contact our medical information service on [number]. On some posts comments are switched off.

Side effects. If your comment or message describes a side effect, we are required to record and report it. We may contact you for details. To report a side effect directly: [Company pharmacovigilance contact]; [TGA reporting link].

Our people. Employees and contractors engaging with these accounts do so under [Company]'s social media policy and identify themselves as [Company] staff.

[Company] Pty Ltd, [City] · Last reviewed [date]

Two closing points of practice, flagged as practice. Anyone who drafts, reviews or approves social content is developing promotional material under § 9(b) and completes the Code component of the Continuing Education Program within their first year. And a social post that names a product is material for review like any other — a § 10.1 statement drafted for LinkedIn is held to § 10.1(e) and § 10.1(g) before it goes, which is what the Reviewer does with it; a post is short enough that it is always tempting to skip the round, and short enough that a breach is the whole of it.