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    How to Choose an Independent Clinical Expert for Your EU Dossier

    October 5, 20266 min readUpdated
    Neta Kela, PhDWritten byNeta Kela, PhDFounder & Managing PartnerFeature image for the PXM article: How to Choose an Independent Clinical Expert for Your EU Dossier

    Short answer: Article 12 of Directive 2001/83/EC requires that the Clinical and Nonclinical Overviews are drawn up and signed by experts with the necessary technical or professional qualifications, and that a brief CV is included. When you appoint an expert, you are choosing the person who will be accountable for the critical assessment of your data. Look for relevant scientific depth, the ability to argue benefit-risk, availability through agency questions, and a CV that will stand up to assessor scrutiny.

    What does Article 12 require?

    The applicant must ensure that the detailed summaries and overviews (Module 2) are drawn up and signed by experts with the necessary qualifications before they are submitted. The expert's CV is included, and the expert's professional relationship with the applicant must be declared. In practice, this means three documents: the signed overview, the expert's signature page and statement, and the CV in Module 1.

    Why the choice matters

    The Clinical Overview is not a summary of Module 5. It is the expert's critical assessment of whether the evidence supports the proposed indication and benefit-risk conclusion. If the assessment is weak, the dossier is weak, however good the underlying data. Assessors read the overview first, and the expert's name is on it.

    What to look for

    1. Relevant scientific background. A drug development or clinical pharmacology background in the product class matters more than writing volume.
    2. Experience with your legal basis. Hybrid and well-established use files need someone who can build a scientific argument with partial data, not only describe a full development program.
    3. Independence and clear accountability. One named expert who personally signs, not a writing team behind an anonymous signature.
    4. Availability after submission. The expert should support responses to the list of questions, because the answers must stay consistent with the overview.
    5. Both overviews in one view. Where the same expert covers Clinical (2.5) and Nonclinical (2.4), the assessment is consistent across modules.

    Questions to ask before appointing an expert

    • Which dossier types and legal bases have you assessed or signed?
    • Will you personally write the critical assessment, or review someone else's draft?
    • How do you handle data gaps you identify during drafting?
    • Will you support us through Day 120 and Day 180 questions?
    • Can you update the overviews for later variations?

    Sources

    • EMA: Pre-authorisation guidance: https://www.ema.europa.eu/en/human-regulatory-overview/marketing-authorisation/pre-authorisation-guidance
    • EUPATI: Marketing authorisation applications: https://toolbox.eupati.eu/resources/marketing-authorisation-applications/
    • EMA: Generic and hybrid applications: https://www.ema.europa.eu/en/human-regulatory-overview/marketing-authorisation/generic-hybrid-medicines/generic-hybrid-applications

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