If you’ve recently heard whispers about VGDs and found yourself wondering whether you’ve missed an important update - don’t worry, you’re not alone.

At the moment, many of us are aware that something has changed in the legislation around vaccine delivery, but haven’t yet seen it play out in practice. So, let’s break it down, what are VGDs, how are they different from PGDs, and where do national protocols fit into all of this?

First things first: what is a VGD?

A Vaccine Group Direction (VGD) is a new legal mechanism introduced in 2026 to support vaccine delivery. If you’re familiar with Patient Group Directions (PGDs), the easiest way to understand VGDs is this:

• A PGD allows one clinician to assess, consent and administer.

• A VGD allows those roles to be split.

That’s the key shift.

Under a traditional PGD, a single registered healthcare professional is responsible for, assessing the patient, providing information, obtaining informed consent, and administering the vaccine. There’s no delegation within that model.

So, what’s different with a VGD?

A VGD allows the clinical decision-making and the administration to be separated. For example, in practice a registered clinician assesses, provides information, gains consent. A second person (who may be non-registered) administers the vaccine.

This introduces formal, legal delegation, which PGDs have never allowed.

But haven’t we seen this before? (Hello, national protocols 👀)

If this is sounding familiar, you’re right.

During the COVID-19 programme, many services use national protocols (for flu too), which also allows separation of roles, involvement of a wider workforce, and non-registered staff to administer vaccines.

So, what’s the difference?

National protocols were introduced during the pandemic, designed for emergency / large-scale delivery .They allow multiple stages of care to be split (assessment, preparation, administration), often include very structured role definitions (e.g. clinical assessor, vaccinator, preparation staff) and are generally time-limited and programme-specific.

Think: “pandemic workaround”

VGDs were introduced into routine legislation (2026). They are designed for ongoing use beyond emergencies. They still allow role separation, but in a more standardised, scalable framework. They are nationally authored (not locally created like PGDs).

Think: “making the workaround permanent”

Why not just keep using national protocols?

Good question - I asked this too. From what I can gather national protocols are incredibly useful, but quite rigid and programme-specific and not designed as a long-term, all-purpose solution. VGDs aim to retain the flexibility, but provide a clearer legal and governance structure that works outside of pandemic settings.

Why has this been introduced?

This is very much driven by workforce and service delivery pressures. We learned during COVID that vaccination doesn’t always need to be delivered by one person from start to finish, and that separating roles can increase efficiency and capacity. VGDs formalise that model so it can be used during seasonal campaigns in community services and potentially in occupational health and other settings.

Does this mean “anyone” can now vaccinate?

No-and this is where some anxiety comes in.

Under a VGD assessment and consent must still be carried out by a registered healthcare professional. The person administering must be trained, competent, and appropriately supervised. So, while roles can be split, accountability remains.

So, when would you use each model?

• Use a PGD when one clinician is managing the whole consultation in a traditional GP or travel clinic setting.

• Use a VGD when you want a team-based approach, you need higher throughput, and you want to safely involve a wider workforce.

• National protocols? Still relevant, but mainly for specific national programmes and large-scale or emergency delivery models.

Although the legislation is now in place, VGDs are not yet widely rolled out in everyday practice. Unlike PGDs, they are nationally authored and not locally developed. And at the moment very few are publicly visible.

So, if you haven’t come across one you’re not behind.

What might this mean going forward?

This is where things get interesting. VGDs have the potential to reshape vaccination service models, expand the role of non-registered vaccinators, and challenge how we approach consent and delegation. They also raise important questions like:

Who holds ultimate responsibility for the decision?

How do we ensure robust consent when roles are split?

What does “supervision” actually look like in practice?

The bottom line

• PGDs: one clinician does everything

• National protocols: pandemic-era, highly structured team model

• VGDs: a new, routine framework allowing safe delegation

Nothing needs to change in your practice unless your organisation tells you otherwise, but this is definitely a space to watch.

Final thought (and a little poem emerged by accident along the way)

PGDs are built around one clinician, and one consultation,

National protocols are built for crisis delivery at scale for the nation,

Written Instructions are not one clinician, nor a moment of crisis; a template for an organisation

VGDs sit somewhere in between:

routine vaccination… delivered by a team.

Reference list

UK Health Security Agency. Understanding Vaccine Group Directions (VGDs). Published March 2026. Available at: https://www.sps.nhs.uk/articles/understanding-vaccine-group-directions-vgds/

UK Government (DHSC). Proposal to amend the Human Medicines Regulations 2012 to support the ongoing supply and deployment of vaccinations across the UK – consultation response. January 2026. Available at: https://www.gov.uk/government/consultations/amend-regulations-to-support-the-supply-and-deployment-of-vaccines/outcome/proposal-to-amend-the-human-medicines-regulations-2012-to-support-the-ongoing-supply-and-deployment-of-vaccinations-across-the-uk-consultation-respon

Specialist Pharmacy Service. Amendments to HMR 2012 supporting vaccine supply and deployment. 2026. Available at: https://www.sps.nhs.uk/articles/amendments-to-hmr-2012-supporting-vaccine-supply-and-deployment/

NHS England. Summary of legal mechanisms for administering COVID-19 and influenza vaccines. 2023 (updated guidance). Available at: https://www.england.nhs.uk/long-read/summary-of-legal-mechanisms-for-administering-covid-19-and-influenza-vaccines/

Specialist Pharmacy Service. Legal mechanisms and their application to give COVID-19 vaccines. 2025. Available at: https://www.sps.nhs.uk/articles/legal-mechanisms-and-their-application-to-give-covid-19-vaccines/ also see Understanding Vaccine Group Directions (VGDs) https://www.sps.nhs.uk/articles/understanding-vaccine-group-directions-vgds/

UK Health Security Agency. National protocol for COVID-19 and influenza vaccination programmes (example programme documentation). Available via GOV.UK: https://www.gov.uk/government/publications/national-protocol-for-covid-19-vaccination-programme (or seasonal influenza equivalents)

Donovan H. Best practice for medicines management and vaccination. Practice Nursing. 2022. (Supports role separation within national protocols)