PV Bulletin
Mhra

UK MHRA refreshes PV procedures and adds decentralised manufacture UK GVP

MHRA updated UK PV procedures (8 Jan 2025), published decentralised manufacture UK GVP (10 Jun 2025), and maintains UK modifications to EU GVP PDFs for UK MAHs.

Primary source: GOV.UK (MHRA asset) – Modifications to EU GVP applying to UK MAHs (earlier version shown)

PV Impact Brief

Urgency: HighConfidence: medium

What changed

MHRA updated UK PV procedures (8 Jan 2025), published decentralised manufacture UK GVP (10 Jun 2025), and maintains UK modifications to EU GVP PDFs for UK MAHs.

Why it matters

Potential impact spans Signal Validation, Risk Management, Local Affiliate Compliance, ICSR Submission, Inspection Readiness, Signal Detection, AI / GxP Governance, Aggregate Reporting, Regulatory Intelligence Monitoring, so Local Safety Officer oversight is needed to maintain compliance readiness and evidence traceability.

Action needed

Mhra update requires triage for Signal Validation, Risk Management, Local Affiliate Compliance; confirm local obligations and document follow-up actions.

Relevant for
Local Safety OfficerSignal Management LeadRegulatory Intelligence LeadPV Operations LeadPV Quality LeadPV Technology / CSV LeadAggregate Reports LeadQPPV
Processes impacted
Signal ValidationRisk ManagementLocal Affiliate ComplianceICSR SubmissionInspection ReadinessSignal DetectionAI / GxP GovernanceAggregate ReportingRegulatory Intelligence Monitoring
Owner

Local Safety Officer

Review cadence

Immediate triage (within 1 business day), then weekly review until closure.

Evidence and confidence

Confidence: mediumSource updated: Jun 10, 2025

Primary-source confirmation recommended before operational implementation.

Full briefing

Practical implication

Mhra update requires triage for Signal Validation, Risk Management, Local Affiliate Compliance; confirm local obligations and document follow-up actions.

MHRA has published/updated UK pharmacovigilance (PV) guidance that UK marketing authorisation holders (MAHs) and service providers should factor into UK compliance planning and inspection readiness.

The immediate operational impact is that teams responsible for UK PV governance and operating processes should re-check the MHRA’s current UK PV procedures page (marked updated 8 January 2025), review the dedicated UK guideline of good pharmacovigilance practices (GVP) for decentralised manufacture (published 10 June 2025), and consider the MHRA-hosted PDFs that describe exceptions/modifications to EU GVP that apply to UK MAHs (one shown as published February 2025, with an earlier version shown October 2023).

The MHRA “Guidance on pharmacovigilance procedures” page is positioned as a UK-facing procedural guide and includes sections spanning general PV operation and multiple core PV activities. Based on the contents shown in the MHRA page, sections include “Actions for submitting and receiving ICSRs,” “Signal detection,” and lifecycle deliverables such as “Risk Management Plans (RMPs),” “Periodic Safety Update Reports (PSURs),” and “Post Authorisation Safety Studies (PASS).” The same page also includes a dedicated section titled “Requirements for MAs granted via the Unfettered Access route,” which is relevant for organisations holding or supporting such UK authorisations.

The PV procedures page also states that a MAH is required to submit pharmacovigilance data to MHRA according to UK requirements. For PV operations and regulatory affairs teams, that framing underlines the need for UK-specific procedural alignment even where organisations run broader EU/ICH-aligned PV systems.

Separately, MHRA has published a dedicated “Decentralised Manufacture: UK Guideline of Good Pharmacovigilance Practices” (published 10 June 2025). The guidance addresses PV aspects for Point of Care (POC) and modular manufacture (MM) medicines and explicitly covers both authorised and unauthorised medicinal products, including Specials and the Early Access to Medicines Scheme (EAMS). The MHRA also describes the decentralised manufacturing context: unlike centrally manufactured products, POC and MM medicines are manufactured outside an established, fixed facility environment, and POC medicines are manufactured in close proximity to the patient. For PV teams, this framing is a prompt to confirm that internal PV governance and documentation adequately cover responsibilities and process interfaces for these manufacturing models.

In addition, MHRA hosts PDFs titled to the effect of “Exceptions and modifications to the EU guidance on good pharmacovigilance practices that apply to UK marketing authorisation holders.” One MHRA-hosted PDF (shown as published February 2025) includes context referencing that the Windsor Framework was agreed in February 2023 and introduced new arrangements for medicines. A separate MHRA-hosted PDF with a similar title (version shown October 2023) contains context about a potential UK leaving the EU without a negotiated withdrawal agreement and references the Human Medicines Regulations. The excerpts provided do not include a detailed change log or the specific operational deltas introduced by these documents; accordingly, PV teams should treat these as compliance reference documents that require an internal delta review rather than relying on assumptions.

What PV teams should do next depends on their UK footprint. For UK MAHs, the practical next step is to ensure that UK PV system documentation (including PSMF references and SOPs) points to the current MHRA guidance and that assigned responsibilities and training reflect UK-specific expectations where they apply. For organisations active in decentralised manufacture (POC/MM) or supporting PV for unauthorised products (including Specials and EAMS), the newly published decentralised manufacture UK GVP guideline is a clear signal to verify PV role interfaces and oversight arrangements in these contexts.

Close: Regulatory Intelligence should complete a targeted delta review of the relevant MHRA guidance and PDFs, with QPPV/PV Quality confirming that UK-specific expectations are embedded in the PV system ahead of the next quarterly UK compliance cycle or any imminent UK submissions/inspections.

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