503A vs. 503B
Two pharmacy categories compound GLP-1s legally:
- 503A pharmacies compound for individual patients based on a patient-specific prescription
- 503B outsourcing facilities compound larger batches and ship to clinics and pharmacies under FDA oversight
Both are legitimate. Both have produced compounded GLP-1s under the FDA shortage exemption that ran through 2024–2025. The payment-processing question is whether the merchant collecting card payment is the prescriber, the pharmacy, the telemed platform, or a marketing intermediary.
Boardable vs. not boardable
From an acquirer's perspective, the boardable model is:
- Patient interacts with a telemedicine platform (licensed in the relevant state)
- A licensed prescriber writes a patient-specific prescription
- The prescription is sent to a 503A or 503B pharmacy
- The pharmacy ships to the patient
- The payment is processed by the telemedicine platform (the entity that holds the patient relationship), not the pharmacy or a downstream affiliate
The not-boardable model is: a direct-to-consumer brand markets GLP-1 to consumers, takes payment without a clear prescriber relationship, and routes orders to a downstream compounding pharmacy. This is precisely the structure Mastercard's BRAM update was designed to catch — acquirers boarding these merchants face per-merchant fines.
The 2024–2025 FDA shortage exemption ending
The FDA declared semaglutide and tirzepatide off-shortage in late 2024 and early 2025, respectively. Compounding under the shortage exemption is no longer broadly available. Compounded GLP-1 sales in 2026 must rely on personalized patient prescriptions, not shortage-driven batch compounding.
How PeptideRails handles GLP-1 merchants
We board telemed-backed GLP-1 platforms with a clear prescriber relationship and 503A/503B pharmacy chain of custody documented in underwriting. We decline direct-to-consumer GLP-1 brands without a prescription path. We also decline brands making comparative claims against approved drugs (Ozempic, Wegovy, Mounjaro, Zepbound) — those claims trigger FDA warning letters and place the entire portfolio at risk.