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On 28 April 2026, the Medicines for Human Use (Clinical Trials) (Amendment) Regulations 2025 came into force after a 12-month implementation period (HRA). The HRA describes it as the most significant package of UK clinical trial reforms in over 20 years, and it applies to every trial of an investigational medicinal product in the UK, including trials that started under the old rules.
The changes affect how applications are made, how safety is reported, which GCP standard applies, and the words used in everyday documents. Here are the seven that most affect sponsors, CROs and sites.
Before and after 28 April 2026
|
Area |
Before |
Now |
|---|---|---|
|
Approvals |
Combined Review run as an administrative service |
Combined Review written into law: one application, one coordinated review |
|
Lower-risk trials |
Same route as other trials |
Notification scheme for some lower-risk initial applications and modifications |
|
Phase I healthy volunteer trials |
Standard route |
A 14-day assessment route |
|
GCP |
Earlier GCP framework |
ICH E6(R3) principles adopted in law |
|
SUSARs and annual safety reports |
Reported to the MHRA and the REC |
Reported only to the MHRA |
|
Transparency |
Registration and results largely by policy |
New legal requirements for registration and results disclosure |
|
Terminology |
"Amendment" |
"Modification" |
1. Combined Review becomes law
Researchers apply for ethics and regulatory approval in one application, through one coordinated review, ending in one UK decision (HRA). Teams that still prepare MHRA and REC packages separately should combine their processes.
2. A notification scheme for lower-risk trials
Some lower-risk initial applications and modifications can follow a streamlined notification route. REC approval is still required for all trials, including these (Latham & Watkins). Sponsors should check which of their trials qualify.
3. A faster route for Phase I healthy volunteer trials
The reforms include a 14-day assessment route for Phase I healthy volunteer studies (Regulatory Rapporteur). Early-phase units can plan shorter start-up, provided documents are ready on day one.
4. ICH E6(R3) becomes the GCP standard
The regulations align UK GCP with ICH E6(R3), bringing its risk-proportionate approach, critical-to-quality focus and data governance expectations into UK law. Sponsors who have not yet run a gap assessment against E6(R3) should start there.
5. Safety reports go only to the MHRA
SUSARs and annual safety reports for all CTIMPs, including those not submitted through Combined Review, are now reported only to the MHRA (HRA). Safety reporting procedures and distribution lists need updating.
6. Transparency moves into law
The regulations introduce requirements for trial registration and results disclosure. Sponsors need a process to register trials and publish results on time, with ownership clearly assigned.
7. "Amendment" becomes "modification"
Changes to approved trials are now called modifications. It sounds minor, but it touches SOPs, templates, CTMS fields, training materials and TMF indexes.
UK readiness checklist
- Map current trials to the new application and modification routes
- Identify trials that qualify for the notification scheme
- Update safety reporting SOPs to report SUSARs and annual safety reports only to the MHRA
- Complete an ICH E6(R3) gap assessment
- Set up registration and results disclosure ownership and timelines
- Replace "amendment" with "modification" in SOPs, templates and system fields
- Brief sites and CROs on what has changed
What this means by role
- Clinical operations directors: plan UK start-up around Combined Review and the notification route, and check portfolio-wide SOPs.
- Regulatory affairs teams: one application now covers ethics and regulatory review.
- Pharmacovigilance teams: update reporting routes for SUSARs and annual safety reports.
- Quality and compliance directors and QA auditors: the E6(R3) gap assessment and SOP updates are inspection evidence.
- eTMF managers: update TMF indexes and document names for "modification".
- CRAs, CRCs and principal investigators: expect new terminology and updated sponsor procedures from April 2026.
How Cloudbyz approaches this
Cloudbyz builds CTMS, eTMF, EDC and Safety & Pharmacovigilance natively on Salesforce, and its eTMF is used by UK-based pharmaceutical and medical device customers. Because fields, workflows and document types are configurable, changes such as renaming amendments to modifications, adding notification-scheme tracking or updating safety reporting routes can be made through configuration rather than custom development. How quickly a given organisation can adapt depends on its existing setup.
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