If you are one of the many small dispensers concerned over meeting the November 27, 2026, Drug Supply Chain Security Act (DSCSA) deadline, you are not alone. Food and Drug Administration’s extension to November 27, 2027 is giving you more prep time, but many DSCSA requirements already apply to your pharmacy today, and have for years. Now is the time to continue your compliance journey to ensure you are ready by November 27, 2027 – the time is sure to pass quickly!
Evolution of DSCSA
DSCSA was signed into law in 2013 and outlined a 10-year rollout to build an electronic, interoperable system to identify and trace certain prescription drugs as they are distributed in the United States. To give trading partners and the industry more time to collaborate on DSCSA implementation, FDA established a one-year stabilization period beginning November 27, 2023. FDA then staggered exemptions for trading partners, most of which have expired.
Today, nearly all trading partners are required to comply with DSCSA. The main remaining exception is FDA’s exemption from certain requirements for small dispensers, first issued in 2024 and extended in August 2026. For purposes of the exemption, a dispenser is considered a “small dispenser” if as of November 27, 2026, the corporate entity that owns the dispenser has a total of 25 or fewer full-time employees licensed as pharmacists or qualified as pharmacy technicians.
This exemption, which stays in effect until November 27, 2027, allows time for FDA to complete the DSCSA Small Dispensers Assessment, publish the final assessment report for public comment, and host a public meeting on the assessment. The survey closed in September.
What are the Current Compliance Requirements?
The current DSCSA exemptions are outlined in FDA’s August 2026 small dispenser exemption letter. They cover the electronic, interoperable requirements; they do not pause the rest. You can meet the remaining requirements with manual or existing methods. As a dispenser, large or small, you must still identify, quarantine, and investigate suspect products today. If you are working with your distributor or a third-party vendor, make sure that you are following these requirements today:
- Buy from and sell to only authorized trading partners.
- Identify, quarantine, and investigate suspect product, and notify FDA and your trading partners if a product is illegitimate.
- Respond to verification and tracing requests from FDA, state regulators, and trading partners.
- Keep DSCSA records for 6 years.
If your pharmacy doesn’t qualify as a small dispenser, you must also exchange and store package-level transaction data electronically and be able to trace and verify products at the package level electronically.
How Pulse Helps you Comply with DSCSA
In July 2026, Pulse by NABP® was made available to dispensers to support streamlined DSCSA compliance. It gives trading partners facility profiles built from state board licensure data, makes it easier to reach the right contact at each partner, and reduces manual administrative work.
| Current DSCSA requirement | What it means in your pharmacy | How Pulse can help |
|---|---|---|
| Buy from and sell to only authorized trading partners (ATPs) | Before you order from a new supplier, confirm they’re licensed and authorized. Suppliers will ask the same of you. | Your ATP status will appear on your profile, so suppliers can easily confirm you. You can check licenses and confirm ATP status on suppliers with an optional Pulse add-on feature. |
| Identify, quarantine, and investigate suspect product | Damaged packaging, an unusual price, or an unfamiliar source? Quarantine the product and verify it before it reaches a patient. | Pulse’s product verification service checks the product identifier with the manufacturer, so you have the manufacturer’s response when deciding whether a product is suspect. |
| Notify FDA and trading partners about suspect product | Know who to contact at each supplier, and how to reach them quickly. | Pulse’s trading partner directory includes the preferred contacts each trading partner lists on its Pulse profile. |
| Respond to verification and tracing requests from FDA, state regulators, and trading partners | Make sure requests reach the right person on your team, not a general inbox. | Name your preferred contacts on your Pulse profile so regulators and partners reach the right person. |
| Keep DSCSA records for 6 years | Know where your transaction data is stored and how to retrieve it. | Pulse doesn’t store records for you, so keep using the system you have in place for your transaction data. Pulse works alongside 15+ DSCSA solution providers. |
Additional Pulse Features
Get even more out of Pulse with the following features:
- The robust Search tool allows you to easily find trading partner contact information with identifiers including Global Location Number (GLN), DEA registration number, National Council for Prescription Drug Programs Identification Number (NCPDP ID), and License Number.
- Set preferences and privacy controls for streamlined communications with trading partners.
How to Get Started
Haven’t signed up for Pulse yet? Dispensers and some distributors are currently onboarding, and regulators are already using the platform. Set up your free account and claim your facility profiles today. To learn more about signing up, visit our FAQs.