{"page":"/blog/pharma-programmatic-advertising","modified":"2026-11-10","license":"https://creativecommons.org/licenses/by/4.0/","columns":["Date","Action","What it says","Status on 9 November 2026"],"rows":[["9 September 2025","Presidential memorandum \"Addressing Misleading Direct-To-Consumer Prescription Drug Advertisements\" (White House)","HHS to increase required risk information \"to the extent permitted by applicable law\"; FDA to enforce the FD&C Act's advertising provisions","Issued; states it creates no enforceable right"],["9 September 2025","FDA and HHS announcement (FDA)","\"Thousands of letters\" to companies; about 100 cease-and-desist letters; rulemaking to close the \"adequate provision\" loophole, which FDA dates to 1997; AI tools to monitor ads","Announced; letters issued"],["9 September 2025 to 26 October 2026","OPDP untitled letters (FDA list)","52 untitled letters dated 9 September 2025; 63 in 2025 and 25 in 2026 to 26 October","Posted; 5 letters were dated 2024 and 4 dated 2023"],["2026 Unified Agenda","\"Transparency in Direct-to-Consumer Advertising\", RIN 0910-AJ14 (reginfo.gov)","Revise 202.1 to remove the adequate provision option for broadcast ads; economically significant; NPRM listed for December 2026","Proposed rule stage; no proposal in the Federal Register as of 9 November 2026"],["5 November 2026","eCFR text of 21 CFR 202.1 (eCFR)","Still allows broadcast ads to rely on \"adequate provision\" for the labeling","In force"]],"sourceUrls":[["https://www.whitehouse.gov/presidential-actions/2025/09/memorandum-for-the-secretary-of-health-and-human-services-the-commissioner-of-food-and-drugs/"],["https://www.fda.gov/news-events/press-announcements/fda-launches-crackdown-deceptive-drug-advertising"],["https://www.fda.gov/drugs/warning-letters-and-notice-violation-letters-pharmaceutical-companies/untitled-letters"],["https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202510&RIN=0910-AJ14"],["https://www.ecfr.gov/current/title-21/chapter-I/subchapter-C/part-202/section-202.1"]]}