Added on 26 January 2024:
'Resumption of clinical data publication for all medicines' section

By proactively publishing clinical data, EMA intends to help:

  • avoid duplication of clinical trials, foster innovation and encourage development of new medicines;
  • build public trust and confidence in EMA's scientific and decision-making processes;
  • academics and researchers to re-assess clinical data.

EMA has developed extensive guidance for industry to facilitate compliance with this policy.

Resumption of clinical data publication for all medicines

EMA has resumed clinical data publication for medicines with new active substances that received a CHMP opinion from September 2023 onwards, or were withdrawn before the opinion stage. 

EMA had temporarily suspended these activities for all except COVID-19 medicines in line with EMA's Final programming document 2023-2025 and its Management Board meeting of 14-15 December 2022

The clinical data packages for non-COVID-19 medicines published following the resumption are available in January 2024 via EMA's clinical data website

More information on the suspension and resumption of these activities:

Final programming document 2023-2025

How to access the clinical data

Users need to visit EMA's clinical data website and log in with an EMA account. They can choose between an on-screen view only or a full download-and-print access. Terms of use apply - please see the clinical data website for details.

What clinical data EMA publishes

The Agency publishes the clinical data submitted by pharmaceutical companies to support their request for marketing authorisation, and which are assessed by the Committee for Human Medicinal Products (CHMP). Clinical data normally include:

  • the clinical overview, providing a critical analysis of the clinical data in the submission package, including the conclusions and implications of the clinical data;
  • the clinical summary, which provides a detailed factual summarisation of all the clinical information submitted;
  • the study reports on the individual clinical studies;
  • three appendices to the clinical study reports, namely the study protocol, the sample case report form used to record information on an individual patient, and documentation of the statistical methods used to analyse the data.

These documents correspond respectively to modules 2.5, 2.7 and 5.3 of the ICH guideline M4 (R4) on common technical document (CTD) for the registration of pharmaceuticals for human use - organisation of CTD - Step 5 (CTD).

EMA revised its policy on publication of clinical data in March 2019, to take account of EMA's relocation to Amsterdam. In the revised policy, the governing law has changed from ‘England and Wales’ to ‘the Netherlands’, and the Amsterdam District Court replaces London as a (non-exclusive) judicial venue:

The policy applies to clinical data submitted to the Agency as shown in the table below, regardless of the outcome of the regulatory procedure.

Regulatory procedureSubmitted to EMA from
As part of a marketing authorisation application (MAA) or
submitted by a third party in the context of a MAA
1 January 2015
As part of a procedure under Article 58 of Regulation (EC) No 726/2004 (medicines for use outside the EU)1 January 2015
As part of new indication or line extension applications relating to existing centrally authorised medicinal products1 July 2015

 

For COVID-19 treatments and vaccines, EMA is publishing clinical data submitted to the Agency as part of any regulatory procedure.

This is because these products follow rapid review procedures and can be subject to early access mechanisms. As a result, companies submit clinical data on a regular basis and within different types of regulatory procedures.

For more information on the policy and its background, including the consultation exercise, see:

 

Exclusions

The policy does not apply to:

  • clinical data submitted to EMA as part of an initial marketing authorisation application before 1 January 2015 or as part of new indication or line extension applications submitted before 1 July 2015;
  • clinical data on centrally authorised products that are not held by EMA (e.g. clinical trials on an authorised product conducted by independent investigators and not submitted to the Agency);
  • clinical data submitted to the Agency for non-centrally authorised products (e.g. in the context of a referral procedure);
  • pharmacovigilance data based on individual case safety reports (ICSRs). Access by third parties to ICSR data is addressed in EMA's EudraVigilance access policy;
  • components of an application that do not fall under the definition of 'clinical data', with the exception of the anonymisation report.

Preparing the data for publication

Clinical reports must be anonymised to prevent patients and professionals who participated in clinical trials from being identified, in order to comply with European legislation on personal data protection. This usually involves redacting personal data; the redaction appears as a light blue box with a black 'PPD' label. EMA publishes the applicant's anonymisation report, which describes the anonymisation methods they used and their impact on data utility.

Companies must also justify the redaction of any commercially confidential information (CCI).

The Agency considers that, in general, clinical data cannot be considered CCI but in limited circumstances study reports may contain CCI, which can be redacted. The redaction appears as a black box with a red 'CCI' label.

EMA reviews the company's redaction proposal and provides recommendations. The company then submits revised documents in line with EMA's recommendations and the Agency publishes the final version. The flowchart below summarises the process.

CT_data_flow.jpg

Technical anonymisation group

The technical anonymisation group (TAG) is an expert group in data anonymisation which includes members from academia, industry, patients and healthcare professionals. EMA established the TAG to help it to further develop best practices for the anonymisation of clinical reports.

For more information on the TAG's membership and responsibilities, see:

Timelines for publication

EMA aims to publish the clinical reports as per the following timelines:

Procedure typePublication timelines
Marketing authorisation, line extension and extension of indication applications60 days after the European Commission decision and following publication of the EPAR.

Article 58 applications

 

within 150 days after the CHMP opinion.
Withdrawn applicationswithin 150 days after the receipt of the withdrawal letter.

 

Please note that there will be some delay in publishing clinical data submitted in 2015 and 2016 while the Agency processes these documents for publication. For more information on current publishing timelines, see Support for industry on clinical data publication.

First report on the implementation of the policy on the publication of clinical data

On 16 July 2018 EMA published the first report on the implementation of the policy on the publication of clinical data.

The report covers one year from the launch of EMA's clinical data website on 20 October 2016. It lists the 54 regulatory dossiers published and the corresponding 50 medicines, which include orphan, paediatric, biosimilar and generic medicines.

The report also includes the results of a user survey of the clinical data website.

Comparison with the Clinical Trials Regulation

Regulation (EU) No. 536/2014 on clinical trials on human medicines (the 'Clinical Trials Regulation') provides a legal basis for the release of clinical trial results conducted in the European Union (EU) and authorised under this Regulation. It entered into application on 31 January 2022. 

The table below compares EMA's policy on the publication of clinical data with the Clinical Trials Regulation in terms of their scope and information published.

 Clinical data publication policyClinical Trial Regulation
Medicinal products coveredCentrally authorised products onlyInvestigational medicinal products regardless of whether they have a marketing authorisation
Clinical studies coveredClinical studies submitted to the Agency in the context of a MAA, Art 58 procedure, line extension or new indication, regardless of where the study was conductedClinical trials conducted in the EU and paediatric trials conducted outside the EU that are part of paediatric investigation plans
Documents publishedClinical data (clinical overview, clinical summaries and clinical study reports) and the anonymisation reportAll clinical trial-related information generated during the life cycle of a clinical trial (e.g. protocol, assessment and decision on trial conduct, summary of trial results including a lay summary, study reports for those trials in the system subsequently included in a marketing authorisation submission in the EU, inspections, etc.)
Publication channelEMA clinical data websiteClinical Trials website
Date it applies1 January 2015 (MAA or Art 58 procedure) or 1 July 2015 (line extension or new indication)

31 January 2022

Publication fromOctober 201631 January 2022

 

The EU clinical trials register also provides publically available summary information on clinical trials conducted in the EU, and paediatric trials conducted outside the EU that are part of paediatric investigation plans. This is the publicly accessible part of the European Union Drug Regulating Authorities Clinical Trials (EudraCT) database

Press briefing

Related documents

Leaflet: One-year anniversary of clinical data publication

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