EU Biotech Act Proposes Sweeping Clinical Trial Reforms to Reverse Europe's Declining Global Competitiveness
Key Insights
The proposed EU Biotech Act aims to shorten multinational clinical trial authorization timelines from 106 days to 75 days, with ATMP trials losing the additional 50-day assessment step entirely.
A strengthened Reporting Member State (RMS) would coordinate scientific, ethical, and regulatory assessments, reducing duplication and improving consistency across Member States.
New risk-proportionate GMO regulations would exempt certain gene therapy trials from full environmental risk assessments, while regulatory sandboxes would support AI-enabled trial innovation.
The European Union is poised to undertake its most significant overhaul of clinical trial regulation since the Clinical Trials Regulation (CTR) entered into force, with the proposed Biotech Act introducing sweeping reforms designed to reverse a decade-long decline in the region's share of global clinical research. The proposals aim to simplify and accelerate clinical trials in the EU, particularly for biotechnology innovation, while maintaining high standards of patient safety, ethics, and data robustness.
The reforms come at a critical juncture. According to IQVIA Institute data, Europe's share of global industry-sponsored interventional Phase I, II, and III trials has fallen markedly between 2019 and 2025, with investment increasingly flowing toward the U.S. and China. "When sponsors decide where to conduct global clinical trials, investment is increasingly flowing out of Europe and into regions like the U.S. and China," notes analysis from The Parliament magazine. "Clinical trials are the gateway to innovation. They determine where investment flows, where patients gain early access to cutting-edge therapies, and where future manufacturing and research capabilities are built."
Shorter Authorization Timelines and a Strengthened RMS
Among the most keenly anticipated changes for sponsors is the proposed reduction in clinical trial authorization timelines. For multinational trials, the current 106-day timeline would be shortened to 75 days, inclusive of validation and ethical review. For Advanced Therapy Medicinal Product (ATMP) trials, the additional 50-day assessment step would be removed entirely. Assessment timelines for substantial modifications would be reduced from 96 days to 47 days, and parallel assessment of independent substantial modifications would be permitted.
The Reporting Member State (RMS) is proposed to take on a significantly strengthened leadership role, coordinating the scientific, ethical, and regulatory assessment across participating countries. Member States would rely on the RMS assessment, intervening only where within the scope of national law, ethical considerations, or national standards of care. This is intended to reduce duplication, improve consistency, and reinforce mutual trust across the EU.
Ethical review would also be more tightly integrated: the ethics committee of the RMS would consolidate ethical input from participating Member States, creating a harmonized and transparent assessment process with fewer divergent national considerations. The Biotech Act also proposes increased use of harmonized templates to bring convergence in submission requirements across EU countries.
Regulatory Streamlining and New Trial Categories
The proposals introduce a new category of Minimal-Intervention Trials, which would apply to studies using authorized products in line with their marketing authorization. Such trials would benefit from risk-proportionate review requiring only ethical approval before they can begin, marking a significant effort to facilitate the work of non-commercial sponsors and encourage post-marketing trials.
Combined trials involving medicines, medical devices, and in vitro diagnostics would gain a dedicated pathway through a single submission within the Clinical Trials Information System (CTIS), significantly simplifying the multiple submissions per Member State currently required.
A single core dossier concept for investigational medicinal products is also proposed, where one Member State would act as a core dossier depository. The first trial's submission documents would become the "core dossier," which could be cross-referenced or updated for subsequent trials, enabling greater efficiency in related trial submissions.
Risk-Proportionate GMO Regulation
One of the key proposals is the elimination of GMO environmental risk assessment (ERA) requirements for certain clinical trials conducted under the CTR. This represents a move away from a one-size-fits-all GMO framework toward a risk-proportionate approach for investigational medicinal products, particularly relevant for gene therapies and other ATMPs used in controlled clinical settings.
Under the proposed amendments to Regulation (EC) No 1394/2007, clinical trials involving GMOs that present no or negligible risk to human health or the environment would be exempt from submitting a full ERA. Sponsors would instead submit a declaration within the clinical trial application explaining why the exemption applies, and the Committee for Medicinal Products for Human Use (CHMP) would verify this declaration.
AI, Digitalization, and Regulatory Sandboxes
The proposal supports the use of artificial intelligence for medicines development and regulation. The European Medicines Agency (search) (EMA) would be tasked with developing non-binding guidance on the deployment of AI and advanced technologies across development and manufacturing, clinical trial design, conduct and analysis, and marketing authorization and post-authorization activities.
Regulatory sandboxes are envisaged to support innovation, allowing sponsors and regulators to test novel trial designs, AI tools, and digital solutions in a controlled environment. Insights from these sandboxes would feed into future guidance and legislative updates.
Data Protection and GDPR Alignment
The amendments aim to harmonize the legal basis for processing personal data under the CTR, aligning more closely with GDPR requirements. Protocols would need to clearly describe data collection and confidentiality safeguards, with sponsors and investigators acting as data controllers. Personal data collected under an authorized trial could be reused by the same controller for other CTR-authorized trials, reducing unnecessary duplication. Member States would be prohibited from introducing additional national data protection requirements beyond those set out in the amended CTR and GDPR.
Support for Innovation and Biosimilars (search)
Beyond clinical trial processes, the proposals include measures to strengthen Europe's competitiveness. Pre-submission advice would be expanded to provide non-committal regulatory and scientific input earlier in development, effectively encouraging smaller biotech company filings in the EU. Supplementary Protection Certificates could be extended for certain medicinal products developed on the basis of two or more clinical trials conducted in the EU. Reduced clinical data requirements for biosimilars (search) would be codified in EMA guidance where robust analytical and non-clinical evidence is available.
The question remains whether these proposals will be sufficient to attract clinical trials back to the region. As IQVIA notes, "Whether these proposals will be enough for the EU to attract clinical trials to the region, and how these measures will compare to efforts being made by countries outside the EU to draw trials into their own regions remains to be seen."