Pharmacy Act 2024 still not in force in the Cayman Islands

In the Cayman Islands, the law that controls which medicines may be brought in and sold is still the Pharmacy Act, 1979. Its replacement exists: Parliament debated the Pharmacy Bill, 2024 in July 2024 and it became Act 8 of 2024. But on 7 November 2026 the government's official legislation website still lists the Pharmacy Act, 2024 under "Not in Force Legislation"². For physicians watching the GLP-1 market fill with online sellers and counterfeits, that gap matters.

A 45-year-old law, and a replacement waiting since 2024

The reform has a long history. A 1991 Pharmacy Act was passed but never commenced; the 2024 Bill repeals both it and the 1979 Act¹. In November 2021 the Auditor General, Sue Winspear, reviewed the Health Services Authority's outpatient pharmacy and wrote that "The Pharmacy Act, which dates back to 1979, is not in line with current good practice and creates risks for the control and regulation of drugs that are able to be brought into the Cayman Islands"⁶. She added that the legislative framework for pharmacy services was "significantly out of date" and that "This needs to be rectified as soon as possible"⁷.

A draft went to public consultation from 29 September to 30 November 2023. The then Chief Medical Officer, Dr. Nick Gent, said it would "close gaps due to the existing Pharmacy Act being so outdated" and help in "stemming the importation of medicines by those without the appropriate licence or authority"; the Minister for Health and Wellness, Sabrina Turner, called it "long overdue"⁵. Reporting in June 2024, Cayman News Service noted that efforts to modernize the law had gone on for nearly 15 years⁴. On 23 July 2024 Ms. Turner moved the second reading, and the House voted unanimously to set the Bill down for a third reading³.

What the Pharmacy Act, 2024 would change

The Bill as published in Legislation Gazette No. 20 of 24 May 2024 sets up a full licensing regime for the import, manufacture, wholesale, dispensing and prescribing of medicines¹. Its key provisions:

• "Approved medicine". A medicine approved in a country prescribed by regulations, approved by the Pharmacy Council, or covered by an exceptional use or emergency use authorization. The memorandum explains that the main route is approval by a corresponding authority in a prescribed country, so the Council would not have to approve each medicine individually¹.
• Who may import. Pharmacists for dispensing, registered practitioners for administering to their patients, licence holders, individuals for self-administration in specified circumstances, and the Chief Medical Officer or Director of Agriculture (clause 3)¹.
• Non-approved medicines. Importing, selling by wholesale, dispensing, prescribing, administering or manufacturing a non-approved medicine is an offence punishable by a fine of twenty thousand dollars, five years in prison, or both (clause 15)¹.
• Retail supply and compounding. Retail supply is limited to pharmacists in certified pharmacies or holders of a dispensing licence (clause 16); compounding is limited to pharmacists, licensed dispensers, and registered practitioners or veterinary surgeons within their scope (clause 17), with the same penalty¹.
• Altered and mislabeled medicines. Altering a medicine's composition to supply it, or supplying falsely or misleadingly labeled medicine, becomes an offence (clauses 18 and 19), and medicines must come with a patient information leaflet in English (clause 20)¹.
• Online sellers. Internet and mail-order pharmacies with no physical premises offering in-person services are banned; a traditional pharmacy may still offer online services (clause 22)¹.
• Enforcement. Inspectors appointed by the registrar get powers of entry, search, sampling and seizure (clauses 32 and 33)¹.

Why the delay matters in the GLP-1 era

The provisions most relevant to today's market (the ban on online-only pharmacies, the offence of dealing in non-approved medicines, and the inspectors' seizure powers) are precisely the ones that do not yet apply¹². In March 2026 the Pan American Health Organization warned that growing demand for GLP-1 drugs may encourage their sale through unofficial channels, including the internet and social media, where products may be "falsified, unauthorized, or substandard" and may contain wrong doses, different active ingredients or undeclared substances¹⁰. In April 2025 the US FDA warned about counterfeit Ozempic (semaglutide) found inside the regulated US supply chain, and told pharmacies to buy only through the manufacturer's authorized distributors¹¹.

Some pieces of the wider system already exist. Under the Health Practice Act (2026 Revision), the Health Practice Commission certifies health care facilities, and operating one without a certificate is an offence punishable by a fine of fifty thousand dollars plus ten thousand dollars for every day (sections 5 and 15)⁹. The Bill itself relies on this, defining a certified pharmacy as one certified under section 5 of the Health Practice Act¹. When Dr. Gent's departure was announced in March 2025, the government credited him with "modernising of pharmacy practices via the updating of the Pharmacy Act and supporting regulations"⁸. The regulations the Act depends on, including the list of prescribed countries and the schedules of pharmacy and prescription-only medicines, are made by Cabinet under clause 41¹.

What physicians in the Cayman Islands should note

Until a commencement order is published, the 1979 Act remains the governing law, and the 2024 Act's offences cannot be enforced²⁶. When it does commence, clause 15 will reach not only importers and sellers but also anyone who prescribes or administers a non-approved medicine, and clause 24 will restrict who may issue prescriptions¹. The Bill also gives clinicians a lawful route for medicines not yet approved: an exceptional use authorization issued by the Pharmacy Council on a prescriber's application when the medicine is safe and effective and exceptional circumstances exist (clause 13)¹. The stakes are real: a review of prescription-drug diversion in North America found it takes many sourcing routes and is a "complex and difficult target for interventions"¹².