Pre-submission interactions model pilot

The European Medicines Agency (EMA) is running a voluntary pilot assessing a revised model for pre-submission interactions for initial marketing authorisation applications.
HumanRegulatory and procedural guidance

EMA is inviting marketing authorisation applicants to take part in an 18-month pre-submission interactions (PSI) model pilot. 

The pilot introduces an earlier, more structured dialogue between applicants, rapporteurs and EMA. 

It aims to improve submission readiness and support more predictable assessment timelines

EMA launched the pilot in September 2026. 

To learn more about EMA's pre-authorisation guidance, see:

Pilot purpose and objectives

The pre-submission interactions (PSI) model pilot introduces shared ownership and early dialogue between applicants, rapporteurs and EMA over the submission timing

This gives all parties better visibility into planning and an opportunity to identify potential issues together before the formal application submission.

The pilot aims to achieve the following:

  • Optimise submission readiness
  • Identify "premature" applications and assessment issues at an early stage
  • Support alignment between applicants, rapporteurs and EMA on realistic submission timelines

It is meant to address cases when applicants submit their marketing authorisation applications before the supporting data package is fully mature. Such cases can lead to delays, clock-stop extensions, or a need for substantial new data submission during assessment. This is why the revised model builds in earlier and more comprehensive dialogue between all parties involved in the procedure.

For more information on pre-submission interactions, see the section on 'Steps prior to submitting the application' - Q&A 2.9.1 on 'How are marketing authorisation application pre-submission interactions structured at EMA? on the 'Pre-auhorisation guidance' page:

Pilot participation

The pre-submission interactions (PSI) model pilot is open to applicants planning to submit an initial marketing authorisation application between February 2027 and September 2028.

Participation is voluntary: applicants, rapporteurs and EMA agree together on which applications to include in the pilot.

Once an application is included in the pilot, the applicant, rapporteurs and EMA are expected to follow the agreed process through to submission. This allows the pilot to generate valuable insights measured against key performance indicators (KPIs). Find out about the related KPIs in the 'Next steps' section on this page.

Getting involved

EMA contacts applicants with an initial marketing authorisation submission scheduled from February 2027 onwards.

Applicants can be pro-active and express their interest even before being contacted. They can do so via their EMA product lead.

In this way, applicants can agree on participation with the relevant rapporteurs and EMA, ahead of the applicable milestone(s).

Revised pre-submission interactions model

The pilot tests a revised pre-submission interactions (PSI) model that builds on the existing pre-authorisation process. 

It adds so-called structured touchpoints between rapporteurs' appointment and marketing authorisation submission.

The timeline below provides a summary of the revised model:

  1. Eligibility request

    18 months before the intended initial marketing authorisation submission date

    Unchanged by revised model.

  2. Request for rapporteur allocation

    9 months before the intended submission date

    Submitted together with an up-to-date development status overview.

  3. Pre-submission interactions (written)

    5 months before the intended submission date

    The revised EMA pre-submission interactions (PSI) form available on this page enables a written exchange with EMA. EMA provides written feedback within 3 weeks of a complete submission.

  4. Joint pre-submission meeting (EUSTART)

    3 months before the intended submission date

    A joint meeting between the applicant, rapporteur(s) and EMA. This is to discuss dossier maturity and confirm submission readiness. EUSTART stands for EU submission, timelines and review talk.

  5. Letter of intent

    2 months before the intended initial marketing authorisation submission date

    This is to confirm the agreed submission date.

Supporting documents

Supporting documents are available to guide applicants through the pre-submission interactions pilot.

Find below brief indications of what each document contains and how it should be used in the pilot:

  • Guidance on the revised pre-submission interactions (PSI) model - full process description and expectations for applicants, rapporteurs and EMA
  • Revised EMA pre-submission interactions (PSI) form - to be completed electronically and submitted via the IRIS portal, together with the required background documents
  • EUSTART (EU Submission, Timelines and Review Talk) - document to help applicants prepare for the joint pre-submission meeting and structure their briefing package
  • Annex to the request for rapporteurship - development status overview to accompany the request for rapporteur allocation

Next steps

EMA is monitoring the pilot's progress against a defined set of key performance indicators (KPIs) covering the following aspects:

  • Effectiveness of the revised PSI model
  • Submission timeline alignment and predictability
  • Process timelines 

EMA plans to produce a report evaluating the pilot's impact.

Future refinements are possible based on pilot findings.

Page update history

An update log is available to show the date and summary of changes to this webpage. It does not include updates to linked documents or minor edits like typos or broken link fixes.

The tracking of updates begins in August 2026.

28 August 2026

Page first published

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