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Table 3 National CTIS requirements and related issues

From: Experiences and challenges with the new European Clinical Trials Regulation

Country

Requirement

Issue

Ireland

Searchable documents without signatures (not scanned documents)

Opposite from the requirement in Italy

Submission of a Data Protection Impact Assessment (DPIA)

Not a pre-defined document, nor has it been requested by other participating countries

Italy

Scanned documents with (ink) signatures

Opposite from the requirement in Ireland

Hungary

Submitted protocol to be signed by all Hungarian investigators.

The submitted version of the protocol will usually be amended during the assessment phase, triggering versioning issues.

Luxembourg

A copy of the eCRF

Operationally it is more efficient to start the eCRF work after submission. To require a version compatible with the approved protocol while said protocol is subject to change induces versioning issues.

Luxembourg and Greece

Signed versions of the clinical trial agreements between the sites and the sponsor

This usually requires the agreement to be fully signed and executed. Many countries will not sign a contract before the application is fully approved, which creates a vicious circle of those who do not want to sign a contract before approval and those demanding signed contracts in CTIS.

Czechia

The full national dossier must be submitted for the transferal application

A clear violation to the requirements set forth in section 11 of the CTR Q&A document.

Spain

A unique, local version of the Site Suitability document

Will not accept the template developed by the EU Clinical Trials Expert Group endorsed by the EU commission.