PV Bulletin
European Medicines AgencyEuropean Union

Post-authorisation safety studies (PASS): Update on Assessment Timelines and Submission Requirements

EMA clarifies the submission timelines and protocol requirements for non-interventional imposed PASS, focusing on draft protocols and the assessment process.

PV Impact Brief

Urgency: HighConfidence: high
Relevant for
Regulatory Intelligence LeadQPPV
Processes impacted
Country Compliance
Action needed

MAHs must ensure draft protocols are placed correctly in the CTD and that submission planning considers the clarified assessment timelines, with RMP updates contingent upon PRAC endorsement.

Owner

Regulatory Intelligence Lead

Review cadence

Review in the next regulatory intelligence cycle.

Policy change details

Document type
Q&A
Policy status
revised
Publication date
2026-07-13
Policy change
The European Medicines Agency (EMA) updated its Questions and Answers on Post-authorisation safety studies (PASS), specifically addressing the assessment timelines and submission requirements for non-interventional imposed PASS.

Key changes

Updated Question 11 clarifies that the assessment of a non-interventional imposed PASS final study report by the PRAC takes up to 74 days, followed by 67 days for the European Commission decision-making process. Updated Question 12 specifies that draft protocols for these studies should be submitted in Module 1.8.2 of the CTD and only included in the RMP once endorsed by the PRAC.

Affected workflows

Country Compliance

Responsible groups

Pharmacovigilance OperationsRegulatory Affairs

PV impact

MAHs must align their submission planning for non-interventional imposed PASS with the clarified assessment timelines. Draft protocols must be correctly placed in the CTD (Module 1.8.2) and RMP updates should only occur after PRAC endorsement.

View regulator source

Source document details

Exact policy details

Effective date of Revision 2
9 August 2016
Applies to: Applicable to submission of information on non-interventional post-authorisation safety studies (PASS)
Date for coming into effect of Revision 2: 9 August 2016. · p. 1 · High · Source
Submission of final study report
12 months after end of data collection
Applies to: Final study report for non-interventional PASS conducted under obligation
The final study report shall be submitted within 12 months after the end of data collection. · p. 2 · High · Source
Submission of study protocol and progress reports
As required by national competent authorities
Applies to: All non-interventional PASS conducted voluntarily
The national competent authority may require submission of the study protocol and the progress reports. · p. 2 · High · Source
Study registration in the EU PAS Register
Before study commences or at earliest possible date
Applies to: Non-interventional PASS
Non-interventional PASS should be registered before the study commences or at the earliest possible date. · p. 2 · High · Source

Workflow rule impacts

Country ComplianceMarketing Authorisation Holders

Need for marketing authorisation holders to adapt to updated submission timelines and protocols

Change in submission requirements for PASS

The submission of the final study report within 12 months after data collection affects the compliance requirements. · p. 2 · High · Source

Evidence and confidence

Confidence: highSource updated: Jul 13, 2026

Full briefing

What changed

EMA established that draft protocols for non-interventional imposed PASS should now be submitted in Module 1.8.2 and aligned submission timelines for assessments are defined as 74 days for PRAC review and 67 days for EC decision.

Why it matters

MAHs need to adjust their planning and submission processes to comply with these updated timelines and requirements, which could significantly impact the speed of study implementation and monitoring of safety signals.

Practical implication

MAHs must ensure draft protocols are placed correctly in the CTD and that submission planning considers the clarified assessment timelines, with RMP updates contingent upon PRAC endorsement.

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