Hamilton, Bermuda, 10th March 2026 – The Bermuda Health Council (Health Council) advises pharmaceutical importers, retailers, and other stakeholders that Phase II of the National Drug Formulary implementation and enforcement has been temporarily paused. During this period, Phase I requirements remain in effect.

This pause will remain in effect while the Health Council undertakes a broader review of recent developments within Bermuda’s pharmaceutical market, including engagement with relevant stakeholders. Details of the original phased implementation approach are available within the Drug Formulary Consultation, Implementation and Enforcement Plan published on the Health Council’s Engagement page.

What This Means for Pharmaceutical Importers and Retailers

During this review period:

• Phase I requirements remain in force, including regulated pricing requirements for generic medicines.
• No enforcement actions related to Phase II medicines will be undertaken while the review process is underway.
• Medicines that fall within Phase II will be addressed following completion of the review and the issuance of updated guidance.

As part of this process, certain medicines previously identified within earlier implementation phases, including GLP-1 therapies such as Ozempic, will be addressed within the Phase II framework pending completion of the review. Stakeholders will be provided with further guidance once the review has concluded.

Why This Decision Was Made 

The pharmaceutical market is currently experiencing rapid changes in purchasing arrangements, pricing structures, and distribution dynamics both locally and internationally. As these developments evolve, the Health Council believes it is important to conduct a broader review to ensure that regulatory implementation remains aligned with the principles of:

• fairness
• transparency
• equitable access to medicines

The review will examine current market conditions, including whether emerging purchasing and distribution arrangements could create unintended consequences such as:

• disparities in access
• pricing distortions
• unfair competitive conditions within the sector

The Health Council will also examine whether aspects of the current regulatory framework require updates to ensure the system continues to operate effectively as the market evolves.

Transparency on the Drug Pricing Framework 

For transparency, the initial National Drug Formulary pricing framework was developed using a structured approach that includes:

• a $1.50 wholesale floor for saleable units
• a 15% wholesale margin on landed cost for high-cost medicines
• a 25% wholesale margin on landed cost for other medicines
• a standard $35 dispensing fee per prescription

As part of the current review, the Health Council will assess whether this structure continues to support the intended policy objectives of affordability, fair competition, and consistent compliance across Bermuda’s pharmaceutical market. The aim is to ensure that the framework operates effectively while avoiding unintended legal or operational gaps that could undermine compliance or market stability.

Review of GLP-1 Medications 

The review will also include GLP-1 medications such as Ozempic and similar therapies, which are currently experiencing significant changes in pricing, demand, and supply dynamics globally.

Given the rapidly evolving international market for these medicines, the Health Council is reviewing the available data and market conditions to ensure that regulatory and pricing decisions remain informed by the most current evidence and market realities.

Regulatory and Legislative Alignment 

As part of the review process, the Health Council will also examine areas where existing legislative and regulatory standards may require clarification or alignment, including provisions within the Pharmacy and Poisons Act and related regulatory frameworks.

This work forms part of the Health Council’s broader efforts to strengthen Bermuda’s pharmaceutical sector and ensure that regulatory structures continue to support a transparent, stable, and sustainable market environment.

The review will also consider barriers that may exist within the current system that affect patient access to essential medicines and pharmacy services, with the goal of identifying practical opportunities for improvement within the pharmacy sector.

What Happens Next 

Once the review process is complete, the Health Council will issue a follow-up advisory outlining:

• the outcome of the review
• any updates to implementation guidance
• a revised timeline for enforcement

As part of this process, the Health Council will also assess whether the current phased implementation approach remains the most effective strategy.

Depending on the findings, Phase II may be consolidated into a broader single-stage rollout rather than continuing with a piecemeal implementation approach, in order to provide greater clarity and consistency for stakeholders. Stakeholders will be given adequate notice prior to any changes to the implementation schedule or enforcement activities