Clinical data publication
As of October 2016, the European Medicines Agency (EMA) publishes clinical data submitted by pharmaceutical companies to support their regulatory applications for human medicines under the centralised procedure. This is based on EMA's flagship policy on the publication of clinical data.
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.
On 5 December 2018, the Agency suspended the publication of clinical data as a result of the implementation of the third phase of EMA's business continuity plan and it remains suspended due to ongoing business continuity linked to the COVID-19 pandemic. EMA is publishing clinical data for COVID-19 medicines in line with its exceptional transparency measures for treatments and vaccines for COVID-19.
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 common technical document (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:
- European Medicines Agency policy on publication of clinical data for medicinal products for human use
- Questions and answers on the European Medicines Agency policy on publication of clinical data for medicinal products for human use
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 procedure||Submitted 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 products||1 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:
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.
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.
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:
EMA aims to publish the clinical reports as per the following timelines:
|Procedure type||Publication timelines|
|Marketing authorisation, line extension and extension of indication applications||60 days after the European Commission decision and following publication of the EPAR.|
|within 150 days after the CHMP opinion.|
|Withdrawn applications||within 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.
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.
Regulation (EU) No. 536/2014 on clinical trials on human medicines (the 'Clinical Trial Regulation') provides a legal basis for the release of clinical trial results conducted in the European Union (EU) and authorised under this regulation. It enters into force in 2018.
The table below compares EMA's policy on the publication of clinical data with the Clinical Trial Regulation in terms of their scope and information published.
|Clinical data publication policy||Clinical Trial Regulation|
|Medicinal products covered||Centrally authorised products only||Investigational medicinal products regardless of whether they have a marketing authorisation|
|Clinical studies covered||Clinical 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 conducted||Clinical trials conducted in the EU and paediatric trials conducted outside the EU that are part of paediatric investigation plans|
|Documents published||Clinical data (clinical overview, clinical summaries and clinical study reports) and the anonymisation report||All 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 channel||EMA clinical data publication website||Future EU portal and database|
|Date it applies||1 January 2015 (MAA or Art 58 procedure) or 1 July 2015 (line extension or new indication)|
|Publication from||October 2016||Planned for end 2021|
Until the Clinical Trial Regulation enters into force, the EU clinical trials register 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 EU clinical trials database (EudraCT). As of 21 July 2014, it is mandatory for trial sponsors to upload results of their trials on the public register.