Online Clinic/Pharmacy Promotional Compliance Assessment & Ongoing Assurance Program
PAAB Website & Digital Content Compliance Assessment:
For Canadian online clinics and pharmacies
Online clinics and pharmacies operate in a highly regulated environment. Website copy, FAQs, intake flows, and patient-facing “educational” content can all create advertising and promotional compliance risk. PAAB offers a practical, Canada-specific service to help you identify issues, remediate efficiently, and maintain ongoing compliance as content evolves.
What this service is
A structured review of your website and in-scope digital content to assess potential non-compliance with applicable Canadian federal requirements governing health product advertising and promotional messaging. If issues are identified, PAAB provides clear, prioritized recommendations to support a path to compliance.
What you receive
1. Compliance Assessment (Written Findings Report)
- Summary of overall risk and key themes
- Page-level findings (where feasible) with references
- Prioritized issues (e.g., High / Medium / Low)
- Practical recommended changes and rationale
2. Remediation Verification (Optional)
After you update the site, PAAB can re-review the revised pages/content to confirm whether all identified issues have been addressed.
3. Ongoing Assurance (Optional)
For organizations that want continuous alignment over time, PAAB offers:
- Internal content governance support: PAAB requests that you implement internal policies and workflows for review/approval of new or revised content; PAAB can review your draft policy and provide feedback.
- Bi-annual website content reviews: Two reviews per year to assess ongoing compliance and identify any corrective actions required.
- PAAB is continuously accessible for project specific billable consultation: Meetings when new campaigns are launching, technology updates, structural changes etc. to provide guidance on how to grow and change compliantly.
Scope of review
Typically in scope (unless otherwise agreed):
- Public-facing webpages and landing pages within agreed domains
- “How it works,” eligibility, pricing, intake flow explanations, and prescribing pathway descriptions
- FAQs, blogs/articles, and educational pages where content may function as promotional messaging
- Testimonials/endorsements as displayed on the website (if applicable)
- Downloadable/embedded materials hosted on the website (e.g., PDFs)
- Paid ads (search/social/display), influencer or affiliate marketing
- Email/SMS campaigns
- Social media channels
- Mobile app content
Out of scope unless added:
- Third-party sites not controlled by your organization
- Internal training material*
*note that while internal training material is not within scope of this project, branded material provided to HCPs through the clinic/pharmacy are considered advertising and are subject to the regulations. Please reach out to PAAB to better understand support offerings.
How pricing works
This service is delivered on a time-and-materials basis. If you solicit the service, PAAB will provide:
- a defined scope (what will be reviewed), and
- an estimated range of hours at PAAB’s hourly rate of $284.00.
PAAB logo option (after compliance is achieved)
If your site is brought into compliance and confirmed by PAAB, you may choose to display a PAAB compliance mark on your website to signal alignment with applicable requirements.
Use of the mark is conditional on:
- maintaining internal content review policies for new/updated content, and
- participating in bi-annual reviews to help ensure ongoing compliance.
- for web assets, a link to a page that contains description of what the PAAB logo means.
If material issues arise and are not remediated within a reasonable period, PAAB may require removal of the mark until compliance is restored.
What you’ll need to provide
- Your website domain(s) and key URLs (or a site map)
- Access to any gated pages you want included in scope (if applicable)
- A point of contact to coordinate questions and remediation
Get Started
To request a scope and estimate, contact PAAB at info@paab.ca with:
- your primary website URL(s),
- a brief description of services/products offered,
- a brief description of marketing tools and tactics,
- any specific areas you want prioritized (e.g., intake flow, FAQs, product/service pages).
Note: PAAB’s review supports compliance decision-making. Final responsibility for content and implementation remains with the website operator and this service does not constitute legal advice.
All materials submitted to PAAB are treated as strictly confidential. They are accessed only by PAAB staff and are never shared outside the review process. PAAB operates under well‑defined confidentiality protocols, secure systems, and long‑standing industry practices designed to protect proprietary content, competitive information, and unpublished data. Our sole use of your materials is to conduct the regulatory review you’ve requested, nothing more.
Rapid Access Consult
When timelines are tight and decisions matter, getting the right feedback early can make all the difference.
Rapid Access Consult is a service designed for teams who need focused, practical guidance.
Why consider Rapid Access Consults:
- Rapid Access: Get quick, actionable feedback from a team of two reviewers to strengthen your submission before it’s filed
- Project-Specific Guidance: Unlike our free general questions, these consults provide insights tailored directly to your planned project, rather than general advice
- Efficiency: Identifying potential compliance issues early can help avoid rework, delays, and unnecessary costs
- Flexibility: Perfect for targeted questions that don’t require a full consultation
- Confidence: Build your submissions and pitches on a stronger foundation for a smoother review process
The details:
- Length: 20-minute billable session with 2 reviewers from relevant therapeutic team
- Mode: Web conferencing via Teams, organized by PAAB
- Output: Succinct written summary provided after the call if recording and transcribing was allowed
- Timing: Rapid scheduling within days of request
- Fee: See the associated fees here. Book with review@paab.ca.
- Scope: Focused on how existing PAAB guidance applies to a client’s specific project. Please provide sufficient background information to PAAB in advance of the call for best results
If you’re looking to move forward with clarity, speed, and confidence, a Rapid Access Consult may be the right first step.
Reach out to review@paab.ca to try out our Rapid Access Consults for your next project.
Intra-Review Collaborative Meetings
When complex questions arise during review, clarity comes faster when everyone is at the table.
Intra-Review Collaborative Meetings bring two PAAB reviewers together with clients to resolve issues in a more efficient, transparent, and team-based way, moving beyond traditional back-and-forth communications to live virtual discussions and presentations.
Why consider Intra-Review Collaborative Meetings:
- Multi-Perspective Assurance: Confidence that outcomes reflect collective reviewer consensus, with two reviewers on each call. This allows you to gain a second perspective as early as you wish in the review process.
- Faster Path to Approval: Clients and reviewers can weigh in live, provide compliance considerations, and avoid delays caused by offline approvals and re-packaging.
- Collaborative Problem-Solving: A constructive, team-like environment to address issues as they arise. Screenshare with your reviewers and brainstorm solutions and multiple options to help you reach your communication goals.
- Flexibility: Available on demand and tailored to your project needs. Request as many sessions as required. Please see associated fee per meeting here.
The details:
- Length: Up to 1-hour call with 2 reviewers including the reviewer on file and another reviewer from the therapeutic team
- Mode: Web conferencing via Teams, organized by PAAB
- Timing: Available any time after a review letter has been issued. Book with review@paab.ca. Clients may purchase unlimited sessions per review
- Fee: See the associated fee here
- Scope: Direct, collaborative group problem-solving around review issues identified in the letter
By incorporating PAAB expertise directly into your review journey, these meetings help resolve issues earlier, align expectations, and keep projects moving forward.
Let’s replace prolonged rounds of revision with collaborative progress.
Reach out to review@paab.ca to try out this service for your next project.
Product Monograph Consults
A strong Product Monograph (PM) is foundational to a successful submission, and early guidance can make all the difference.
PM Consults provide focused, practical feedback to help sponsors align expectations, clarify requirements, and strengthen their approach before or during project development.
Why consider a PM Consult:
- Gain early insight into key considerations that may impact post-market review
- Reduce uncertainty and enhance campaign planning and execution certainty by addressing questions related to your PM upfront
- Build confidence that your PM is grounded in current expectations
- Support a smoother, more efficient advertising pre-clearance process
The details:
- Length: Up to 1-hour call with 2 reviewers from the relevant therapeutic team
- Mode: Virtual (MS Teams)
- Timing: Any time before or after product launch when a Product Monograph is in development. Book with review@paab.ca
- Fee: See the associated fee here
- Scope: Focus on evaluation of specific wording or data within a draft Product Monograph and whether this Product Monograph would support desired future promotional claims or presentations
Reach out to review@paab.ca to try out our Product Monograph Consults for your next project.
Messenger for Pre-Clearance Review
Messenger is an additional service available for all submissions that allows you to communicate directly with your reviewer within your eFiles APS documents.
It provides quick, informal access to your reviewer for clarification on specific questions and pivotal segments of your submission in between rounds of review.
Why consider Messenger:
- Messenger can help reduce the number of resubmissions to approval by giving you the opportunity to obtain binding review decisions on pivotal segments of your piece in between rounds of resubmission. It can be very helpful when messages or copy can impact other parts of the APS.
- Reviewers will continue to be available for live ticket phone calls to provide clarification on revision requests. However, binding review decisions are not provided over the phone. Only written correspondences, including the Messenger functionality, provide the opportunity for binding decisions.
The details:
- Length: Each fee package provides 5 messages directed to your Reviewer, for use over the entirety of the submission it was requested for. Please note that messages between your team or between the agency and the client are not counted toward this total. There is no limit on the amount of packages that can be purchased.
- Mode: Instant message type feature built directly onto the APS.
- Timing: Response within 1-business day
- Fee: See the associated fee here.
- Scope: PAAB Messenger enables asynchronous back-and-forth between the submitter and the assigned reviewer so that specific questions can be clarified efficiently during the review process. Through this feature, reviewers can also provide binding decisions on particular segments of a piece before the file is resubmitted, helping streamline revisions and reducing delays in reaching overall approval.
To request Client Messenger, select ‘yes’ on the submission form field ‘Request Messenger Fee'. Messenger can also be requested after initial submission by contacting review@paab.ca.
One-Hour Consults
Traditional One-Hour Consult Meetings provide a structured, in-depth discussion on defined topics. They are well suited for strategic questions, interpretation of guidance, or planning next steps.
Why consider One-Hour Consults:
- Clients may find it helpful to arrange meetings with the PAAB to go over advertising concepts, advertising review files, distinguishing advertising versus information, pre-launch information/materials, etc.
The details:
- Length: 1-hour billable session with 3-4 reviewers from relevant therapeutic team
- Mode: Web conferencing via Teams, organized by PAAB
- Timing: Within 2 weeks of client request
- Fee: See the associated fee here
- Scope: An exploration of how existing PAAB guidance applies to a client’s specific project. Similar in principle to Rapid Access Consult, a 1-hour consult allows more time for collaboration and discussion
Book your next One-Hour Consult by forwarding meeting requests to review@paab.ca.
Written Opinions
PAAB offers a Written Opinion Service designed to help clients understand the PAAB Code better, make compliant decisions and to provide direction during project development. Opinions can be requested:
- To clarify what is advertising subject to the regulations
- To clarify exemption from review
- To receive guidance on the acceptability of concepts
- To clarify linkage of material
- To receive guidance on the acceptability of references for product claims.
- To clarify contextual issues
Only one opinion letter is provided per opinion submission. If clarification is needed about anything written in that letter, the PAAB review staff will respond to requests by telephone. 5-10 minute calls are generally sufficient. Final approval would be provided only after completion of pre-clearance review.
Why consider a Written Opinion:
- Opinion submissions provide clear, written guidance on the direction of proposed pharmaceutical advertising and promotional materials.
- Through a timely, confidential review process, PAAB offers opinions to help stakeholders assess the use of studies, guidelines, or understand how specific concepts or executions may align with the PAAB Code, supporting compliance and reducing regulatory risk early in development.
The details:
- Mode: Submitted via eFiles by client in written format
- Output: Written opinion response
- Timing: 4-day turnaround time from time of submission.
- Fee: See the associated fee here
- Scope: Opinion submissions provide clear, written guidance on the proposed pharmaceutical advertising and promotional materials activity presented.
Clarification Calls
Clarification calls are short, 10-15 minute calls that happen within the context of a specific comment with your reviewer on a specific file through eFiles. These are included within the cost of the review and should be limited to one call per round of review. Clarification calls are used to clarify points in your review letter to help move the file forward and reduce rounds of revision.
The details:
- Length: 10-15 minute call with 1 reviewer associated with the submission
- Mode: Teleconference. No video or screensharing currently available
- Output: Clarity regarding an ongoing review issue
- Timing: Within 1 business day of call request
- Fee: No additional fee
- Scope: These calls are intended to provide clarification on ongoing review issues between rounds of revision
Escalation Calls
Escalation Calls
are calls with the Director of Preclearance Services intended to address review issues that have reached an impasse. Please note that escalation calls should only be requested after attempts have been made to resolve issues in writing and over the phone with the primary reviewer on the file. Refer to the "Guidance on eFiles Ticketing & Tagging" for additional information on how to create a ticket request for an Escalation Call.
The details:
- Length: Up to 1 hour with the Director of Preclearance Services and the reviewer associated with the file
- Mode: Teleconference
- Output: Resolution of review issue that has reached an impasse
- Timing: Scheduling within days of request
- Fee: No associated fee
- Scope: To address review issues that have reached an impasse with the reviewer on the file. These calls must include the agency (if applicable) and the manufacturer as they are intended to reach a resolution of the review issue
General Questions
General Questions are 5-minute, non-billable calls where reviewers can explain the meaning of existing PAAB guidance as it relates to general scenarios.
Why consider General Questions:
- General questions are great for getting clarification on specific elements of the Code such as “What is a consensus guideline?” or “How would we validate the use of international guidelines?” These are broad questions that speak to understanding the Code.
- Questions like “Can I use guideline XXX from Germany” or “Would it be ok if I link APS X to APS Y” would not be considered general questions as they are about specific issues and executions.
The details:
- Length: 5-minute call with a PAAB reviewer
- Mode: Teleconference
- Timing: A PAAB reviewer will call within 1 business day of request
- Fee: No associated fee
- Scope: Clarify how existing PAAB guidance or the PAAB code applies to general scenarios
PAAB Forum
Forum Update: Supporting Community-Led Discussion
The forum was created as a space for shared learning and peer support, and as the community grows, we want to lean more fully into that purpose.
Going forward, PAAB will be taking a more listening-first role in forum discussions. Rather than responding immediately to every question, we’ll be encouraging members to engage with one another, share experiences, and help build collective understanding.
PAAB will continue to monitor conversations and will step in to:
- Correct any misunderstandings
- Provide guidance when questions remain unanswered after a few days
- Support discussions where official clarification is needed
Our goal is to foster a collaborative, trusted community where knowledge is shared and strengthened by everyone’s contributions.
Thank you for being part of the conversation.
