Support for industry on clinical data publication
The European Medicines Agency (EMA) has developed detailed guidance for pharmaceutical companies on the requirements to comply with its policy on the publication of clinical data.
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. Pharmaceutical companies should contact EMA as soon as possible concerning publication of clinical data if they plan to submit an application for a COVID-19 related product.
EMA has stopped sending 'invitation letters' and will contact applicants prior to the restart of clinical data publication.
EMA first published guidance in March 2016 and is updating it on a regular basis. Current and past versions of the guidance as well as the list of changes between published versions can be found below:
- External guidance on the implementation of the European Medicines Agency policy on the publication of clinical data for medicinal products for human use
The external guidance provides further information on:
- the scope of the policy as regards clinical reports submitted as part of other regulatory procedures, informed consent applications and duplicate marketing authorisations, as well as definitions (in chapter 1);
- the procedural aspects related to the submission of clinical reports (in chapter 2);
- anonymising clinical reports (in chapter 3), including a template for the anonymisation report (in annex 1.2);
- how to identify and redact commercially confidential information in clinical reports (in chapter 4).
Companies should provide justifications for redactions of commercially confidential information by using the following template:
EMA has developed a question-and-answer (Q&A) document to expand on issues addressed in the external guidance and in discussions with applicants. It addresses a number of questions concerning procedural matters including timelines, commercially confidential information and the anonymisation process. For more information, see:
It will be revised regularly to reflect updates.
EMA held a series of briefings and consultations to support stakeholders in implementing the policy:
- Industry associations webinar: update on the implementation of European Medicines Agency policy on publication of clinical data - Policy 0070 (29/01/2018)
- Update on the implementation of policy on publication of clinical data (Policy 0070) – Industry associations webinar (29/06/2017)
- Update on the implementation of EMA policy on publication of clinical data (Policy 0070) and draft revisions guidance to industry - industry associations webinar (23/03/17)
- Update on the implementation of EMA policy on publication of clinical data (Policy 0070) and proposed revisions to the guidance to industry – Industry associations webinar (9/12/2016)
- Second stakeholder meeting on the implementation of the European Medicines Agency's policy on publication of clinical data for human medicines (7/9/2015)
- Meeting on redacting commercially confidential information (CCI) in clinical reports and anonymising clinical reports for the purpose of publication (6/7/2015)
- Current status of European Medicines Agency policy on publication of clinical data - Stakeholder webinar (24/6/2015)
Agendas, meeting reports, presentations, question-and-answer documents and available video recordings are provided on the meeting pages.
Micro, small and medium-sized enterprises (SMEs) are entitled to a free redaction tool license valid for a period of 12 months to allow companies enough time to prepare the final redacted version. The application letter template for the free redaction tool is available in annex 1 of the external guidance.
SMEs should contact the SME office 5 months prior to the CHMP opinion to apply for the free redaction tool license. The SME office can also provide further guidance on the EMA's policy on the publication of clinical data.