📘 Regulatory basis
Both the Code of Practice for Wholesale Dealers and the Code of Practice for the Guidance of Pharmacy have extensive provisions on the specific physical requirements for “premises”. A virtual office clearly cannot meet any of them. The licence application form also expressly requires a physical business address.
📗 Drew Tang's recommendations
We recommend that clients clearly distinguish between the two concepts: the company’s registered address may be a company secretarial firm’s address or a virtual office selected for convenience; however, the licensed address for the medicines licence must be a fully compliant physical warehouse or shop into which you have invested heavily and made careful preparations. Ensure that these two addresses are not confused on any form.
📕 Risk notice
The risk lies in confusion about the meaning of “address”. Incorrectly declaring a virtual office address in a licence application could not only result in rejection, but also cause the regulator to question your professionalism and seriousness. This may have an unnecessary negative impact if you later reapply using a genuine address. This elementary mistake should be avoided altogether.