What a pharma digital banner must carry in India
UCPMP 2024 applies to every promotional banner. A banner shown only to verified prescribers to inform a prescribing decision carries the Clause 3.2 minimum information. An open banner is also public advertising, governed by the Drugs and Magic Remedies (Objectionable Advertisements) Act 1954 and the Consumer Protection Act 2019. The Drugs and Cosmetics Rules 1945 bar advertising Schedule H, H1 or X drugs without previous Central Government sanction. Their text sets no audience limit.
In short
- Settle the audience before the creative. It changes which further instruments apply.
- Gated to prescribers and meant to inform a prescribing decision: UCPMP 2024 Clause 3.2, all five items. The Drugs and Magic Remedies Act 1954 still applies unless its Section 14(c) saving covers the banner.
- Open to the public: the Drugs and Magic Remedies Act 1954 and the Consumer Protection Act framework, on top of UCPMP 2024.
- Whatever the audience, check the Schedule. Drugs and Cosmetics Rules 1945 licence conditions bar advertising Schedule H, H1 or X drugs without previous Central Government sanction (Rules 74(p), 74A(i), 74B(7), 78(q) and 78A(8)). The text sets no audience limit. How it applies to a prescriber-only banner is a question for your regulatory team.
- Format size never reduces the requirement. It reduces what the banner can responsibly claim.
- A point size is meaningless on a responsive banner. The Code asks for legibility.
The audience changes which instruments apply
UCPMP 2024 applies to all promotion. Clause 3.1 says: 'Any promotional material issued by an authorized holder, or with his authority, must be consistent with the requirements of this Code'. Clause 3.2 adds the minimum information where the material informs a prescribing decision by persons qualified to prescribe. A banner anyone can see is also advertising to the public. So further instruments apply on top of UCPMP 2024. They are the Drugs and Magic Remedies Act 1954, and the Consumer Protection Act 2019 with the Central Consumer Protection Authority's 2022 guidelines.
One condition is written without any audience limit. Under licence conditions in the Drugs and Cosmetics Rules 1945, no advertisement of Schedule H, H1 or X drugs may be made without previous Central Government sanction. Rules 74(p), 74A(i), 74B(7), 78(q) and 78A(8) all carry it. Without that sanction, an open banner for those drugs is ruled out. No disclaimer placed on it changes that. How the condition applies to a banner confined to prescribers is a question for your regulatory team.
A gate does not settle everything either. For doctor material, the relevant saving in the Drugs and Magic Remedies Act is Section 14(c). That covers an advertisement 'sent confidentially in the manner prescribed under section 16 only to a registered medical practitioner'. The saving names only registered medical practitioners, and it needs the manner prescribed under the Act's rules. Whether a web login meets the Section 14(c) condition is a question for your regulatory team.
Where the claim goes when the banner cannot hold it
Clause 3.2 requires the minimum information to be legible and an integral part of the material. In practice, many teams handle this with a banner that makes no efficacy claim. That banner still names the company and shows the generic name next to the brand name. It links to a gated page that carries the claim, its evidence and the full Clause 3.2 information. Clause 3.1 still applies to the banner itself. Whether a given banner informs a prescribing decision, and so needs Clause 3.2 on the banner, is decided by its purpose. Its size does not decide it.
Point sizes do not travel to the web
A point size is a print measure. A responsive banner renders in CSS pixels at a viewport the designer does not control. The Code asks for legibility, which on a banner means judged against its rendered size and contrast. A number carried over from print says nothing about that.
Frequently asked questions
Can a digital banner for a prescription medicine run on an open website in India?
Not for a Schedule H, H1 or X drug without the previous sanction of the Central Government. Under the Drugs and Cosmetics Rules 1945, that is a condition of drug manufacturing licences. Rule 74(p) says no advertisement of those drugs 'shall be made except with the previous sanction of the Central Government'. Rule 78(q) and other licence conditions say the same. Separately, the Drugs and Magic Remedies (Objectionable Advertisements) Act 1954 bars drug advertisements for the purposes and diseases in Section 3 and its Schedule. Its Section 4 bars misleading drug advertisements. UCPMP 2024 applies to all promotion. A banner shown only to verified prescribers that informs a prescribing decision must also carry the Clause 3.2 minimum information.
What must a gated doctor banner carry?
Where its purpose is to inform a prescribing decision, UCPMP 2024 Clause 3.2 applies. It needs the relevant drug and the name and address of the authorisation holder, or of the business responsible for placing the drug on the market. It needs the name of the drug with a list of active ingredients, using the generic name, immediately adjacent to the most prominent display of the drug name. It needs the recommended dosage and method of use, and the method of administration where not obvious. It needs the adverse reactions, warnings, precautions for use and relevant contraindications. Last, it needs a statement that additional information is available on request, with the date the particulars were generated or last updated.
Is there a minimum font size for a digital banner disclaimer?
No. A point size is a print measure and the Code sets none in any case. It requires the information to be legible, which on a responsive banner is judged against rendered size and contrast.
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