Google's 2025 HCP targeting changes, read for Canadian pharma

Google rewrote its rules on personalised advertising to healthcare professionals across three dated steps in 2025: May 29 (announcement), July 1 (Restricted Drug Terms exclusion takes effect), October 29 (enforcement of a new prescription-drug certification in Canada, the United States, and New Zealand). For Canadian pharma, this opens Customer Match, Remarketing, and Similar Audiences against HCP lists. The Food and Drugs Act, PAAB, and the Innovative Medicines Canada code did not change.

The 2025 changes to Google’s HCP advertising policy came in three steps, across two policy documents. The summer-2025 shorthand is broadly correct: pharma can now use personalised audiences to reach physicians on Google. What’s underneath that headline determines whether a Canadian campaign clears review at the platform, at PAAB, and under the Food and Drugs Act.

The three-step 2025 timeline

The change touches the Personalized advertising policy (which governs how audiences can be assembled) and the Healthcare and Medicines policy (which governs what can appear in ads). Three dates:

The May 29 notice is the source document. Posted at support.google.com/adspolicy/answer/16258024, it reads:

The Health sensitive interest category has been updated to clarify the exclusion of “content directed at healthcare professionals in their professional capacity.”

The Restricted Drug Terms sensitive interest category will be updated to exclude “content directed to healthcare professionals in their professional medical capacity.” Effective: July 1, 2025.

Everything downstream (the certification, the agency letter, the October enforcement schedule) follows from those two paragraphs.

What was off-limits before

Until May, Google treated the audience itself as sensitive. Any “Health” interest signal, and any “Restricted Drug Terms” signal, was excluded from personalised targeting across the board. For Canadian pharma, the practical consequences:

• Customer Match against a list built from the Canadian Medical Association’s physician database, provincial licence rolls, or an IQVIA dataset was not permitted. The list was treated as health-sensitive and refused for personalised serving.
• Remarketing on HCP-facing properties was off the table. A visitor to a branded prescriber portal or a Canadian HCP product site could not be re-engaged with a personalised follow-up creative.
• Similar Audiences modelled against an HCP seed was excluded for the same reason: the seed list was sensitive, so the lookalike was off-limits.
• Interest-category overlay on prescription drug terms was not available, even where the keyword itself was permitted.

Canadian pharma media buyers running professional-audience campaigns spent on contextual signals (publication, query, page) and gave up the personalised-audience layer. The Canadian endemic HCP environments (CMAJ, the EnsembleIQ healthcare titles, Medscape Canada) absorbed the budget that Google would not take.

What is now permitted

After July 1, 2025, the following are allowed when the audience is licensed Canadian healthcare professionals in their professional capacity:

• Customer Match against HCP lists. Customer Match accepts hashed email addresses, phone numbers, and mailing addresses; the credentialling step is the source list. CMA-derived physician data, provincial licence-derived lists (CPSO, CPSBC, CPSA, and the equivalents), and IQVIA or comparable datasets are the standard inputs.
• Remarketing to visitors of HCP-gated properties: branded prescriber portals, MSL request pages, sample-request flows, professional registration journeys.
• Lookalike or Similar Audiences modelled from HCP seeds.
• Interest- and affinity-category targeting that overlays Health signals on professional-audience campaigns.
• Restricted Drug Terms as keyword and ad-copy elements in prescription-targeted campaigns, subject to the certification described in the next section.

The phrase that does the work is in their professional capacity. Google’s stated rationale, surfaced in industry coverage, is that an HCP receiving information about a prescription product as part of their work is not the end consumer of that product. The privacy logic that drove the original sensitive-category exclusions (HIPAA in the United States, PIPEDA and provincial overlays in Canada) does not apply in the same way when the audience is a prescriber reviewing therapeutic options rather than a patient researching a condition.

That distinction is the load-bearing assumption of the policy change.

The certification gate

The October step is the one that requires operational work. The Healthcare and Medicines policy update covers advertisers in Canada, the United States, and New Zealand who plan to use prescription drug terms anywhere in the campaign: ad copy, landing page, or keyword list.

What a Canadian advertiser has to do:

1. Apply for a Healthcare and Medicines certification through the advertiser portal.
2. Attest to compliance with applicable federal, provincial, and self-regulatory standards. In Canada that is the Food and Drugs Act and its regulations, PAAB pre-clearance for branded HCP-facing creative, and (for Innovative Medicines Canada members) the IMC Code of Ethical Practices.
3. Where an agency is running the campaign on behalf of a healthcare organisation, submit a letter of authorisation from that organisation. Industry coverage from agencies that have gone through the process describes a Google-supplied LOA template, signed by the manufacturer’s regulatory or marketing lead and uploaded by the agency as a PDF. The template is not published on Google’s policy page; the route in is via the certification application itself or the Google Ads account team.
4. Submit the marketing information (customer lists, websites, advertisements) for compliance verification before the personalised tools unlock.

Industry reporting describes a four-to-six-week ramp on enforcement and a seven-day warning before account-level suspension. Markets outside the Canada, US, and New Zealand scope are not part of the certification path, because Google’s underlying policy on prescription drug promotion in those markets remains generally prohibited, with narrow exemptions for non-promotional uses (public health notices, academic research). The 2025 change is regional, sitting on top of local pharma-advertising regimes.

What did not change

A few things often get rolled into the summary that the policy did not actually touch.

Consumer-directed prescription drug rules in Canada are unchanged. Section C.01.044 of the Food and Drug Regulations still limits consumer-facing advertising of prescription drugs to the drug’s name(s), price, and quantity. Reminder ads (under C.01.044) and help-seeking messages (under Health Canada’s Distinction Between Advertising and Other Activities guidance) sit in different regulatory frameworks but are both unchanged by the 2025 Google policy update.

PAAB review is unchanged. Branded HCP communication for prescription drugs in Canada still goes through PAAB, the only pre-clearance service Health Canada recognises for HCP-directed health product advertising. The Google certification is a platform-level layer that sits on top of, not in place of, the PAAB Code of Advertising Acceptance and the medical and regulatory review the brand team already runs.

The Innovative Medicines Canada code is unchanged. IMC member companies still follow the IMC Code of Ethical Practices on HCP interactions and marketing materials. The 2025 Google change does not loosen any provision of the IMC code; if anything, it puts more pressure on the code’s interpretation in digital channels because the targetable surface area just expanded.

PIPEDA and provincial privacy rules are unchanged. The federal privacy framework, plus provincial overlays (Quebec’s Law 25, Ontario’s PHIPA in clinical contexts, British Columbia’s PIPA, Alberta’s PIPA), still govern collection, use, and disclosure of personal information used to build HCP lists. The 2025 change addresses one specific exclusion in personalised audience eligibility; it does not change the consent and notification obligations for assembling the audience in the first place.

What can be claimed in ad copy is unchanged. Restricted Drug Terms certification permits use of the term in keywords, copy, and landing pages where local law allows. It does not change which claims are allowable under PAAB or under the Food and Drugs Act.

The role of endemic Canadian HCP networks is unchanged in kind. CMAJ, the EnsembleIQ healthcare titles (the Medical Post, Pharmacy Practice+, Profession Santé for French-speaking HCPs), Medscape Canada, and similar inventory still hold the credentialled, peer-network, clinical-context advantages they have always had. The 2025 change makes Google a viable second lane, not a replacement.

Things to verify before launch

A short list, weighted toward the things that trip Canadian campaigns at platform review:

1. The Customer Match audience must be HCP-credentialed, not a consumer list with a healthcare interest signal. Document the provenance: CMA Masterfile derivation, provincial licence roll, IQVIA Brogan output, or a similar credentialled source.
2. PAAB pre-clearance is the long pole on creative. Schedule it ahead of the Google certification, not in parallel; Google will ask for the marketing information and the cleanest version is the PAAB-cleared version.
3. The Google certification application takes weeks to clear, not days. If a launch is on the calendar, it is the long pole on platform.
4. Agencies need the LOA signed by the manufacturer’s regulatory or marketing lead before submission. Most delays here are signature-routing, not policy.
5. Quebec language requirements apply. The Charter of the French Language, as amended by Bill 96, requires French in commercial advertising in Quebec, including digital ads served to Quebec audiences. The compliance deadline for the digital-presence rules was June 1, 2025; penalties run from $3,000 to $30,000 per violation. Plan a French version of any creative that will run with provincial reach, and document the version control.
6. Privacy obligations clear separately from the platform certification. Confirm PIPEDA-compliant consent for any list source that originated from a non-public dataset; in Quebec, confirm Law 25 obligations for the assembly and use of the list.
7. The May 29, 2025 personalised-advertising notice and the current Healthcare and Medicines policy are the authoritative platform-side documents. Industry summaries (this one included) compress and paraphrase.

What this means for media planning

The substantive consequence for Canadian pharma is that media buyers can now run an HCP audience strategy on the same platform stack that runs the rest of the digital programme: Customer Match against a CMA-derived list, Remarketing on a branded HCP portal, Similar Audiences modelling, YouTube reservations against the same audience seeds. Google sits in direct comparison with the Canadian endemic HCP environments for budget that previously had nowhere else to go.

The questions that follow are not policy questions. They are media-planning questions: which performance signals translate cleanly between an EnsembleIQ placement and a Google Customer Match campaign, how attribution settles between a branded HCP portal visit and a Search conversion, what kind of frequency capping survives the move from credentialled environments to general-purpose ad infrastructure. Those belong in a strategy piece.

For the policy itself, what matters is the three dates. May 29, July 1, October 29.

Source documents and further reading

• Google Ads — Update to the Personalized advertising policy (May 2025)
• Google Ads — Update to Healthcare and Medicines Policy (July 2025)
• Justice Canada — Food and Drug Regulations, Section C.01.044
• Health Canada — Illegal marketing of prescription drugs
• Health Canada — Guidance on the distinction between advertising and other activities for health products
• Pharmaceutical Advertising Advisory Board — PAAB Code of Advertising Acceptance
• Innovative Medicines Canada — 2022 Code of Ethical Practices
• Office of the Privacy Commissioner of Canada — PIPEDA guidance on consent and personal information in marketing
• Accelerated Digital Media — Google Ads Policy Changes Allow Health Brands to Target Healthcare Professionals
• Odyssey New Media — Google’s New Certification for Prescription Drug Advertising