This page sets out the Clinical Trials of Investigational Medicinal Products (CTIMPs) regulatory changes which are applicable to City St George's and GESH NHS, effective from 28 April 2026.
At a glance: What's changing
Key changes to ICH E6(R3) and UK CTIMP Regulations
| Update legal framework | Risk-proportionate GCP | Strengthened oversight | Simplified safety reporting | Flexible trial delivery |
| SI 2025/538 updates to the UK CTIMP legal framework |
RBQM, QbD and critical-to-quality factors embedded |
Sponsor and investigator accountability clarified |
Proportionate SUSAR and DSU reporting arrangements |
Decentralised and innovative trial elements enabled |
| Applies to all CTIMPs hosted/sponsored by JCRO |
Applies to all CTIMPs hosted/sponsored by JCRO |
Applies to all CTIMPs hosted/sponsored by JCRO |
Applies to all CTIMPs hosted/sponsored by JCRO |
Applies to all CTIMPs hosted/sponsored by JCRO |
Browse the sections below to find out more.
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From 28 April 2026, updated UK regulations governing Clinical Trials of Investigational Medicinal Products (CTIMPs) come into effect. These changes revise the national legal framework and formally embed ICH E6(R3) Good Clinical Practice (GCP) principles into UK law.
These updates apply to all CTIMPs hosted, sponsored, or supported through JCRO — including those sponsored or hosted by GESH NHS and City St George's University of London.
- Risk-Proportionate GCP: Revised Good Clinical Practice requirements with a stronger emphasis on risk-proportionate trial conduct, Quality by Design (QbD), and data integrity.
- Investigator Responsibilities: Updated expectations for investigator oversight, delegation, and training — with clearer accountability at site level.
- Safety Reporting: Simplified and more proportionate SUSAR and Development Safety Update (DSU) reporting arrangements to reduce administrative burden without compromising safety.
- Flexible Trial Delivery: Greater flexibility to support decentralised and innovative trial elements, including remote monitoring and digital solutions.
- Legislation: Updated statutory basis under the Medicines for Human Use (Clinical Trials) Regulations (as amended, SI 2025/538).
If you work on CTIMPs within JCRO (GESH NHS or City St George's)
- Review and update study documentation as required — including protocols, participant information sheets, consent forms, monitoring plans, delegation logs, and site SOPs.
- Ensure GCP training is current. If your last GCP training was completed more than two years ago, a refresher is required via the NIHR Learning Management System.
- Sponsors or sponsor-delegated teams will contact study teams directly where specific changes are needed to maintain compliance.
If your CTIMP is externally sponsored
- Check whether your sponsor has issued transition or implementation guidance.
- Contact the JCRO Governance & Sponsorship team if you need support reviewing local processes, oversight arrangements, or safety reporting pathways.
- Updated SOPs, templates, and guidance documents — released ahead of the April 2026 go-live
- Briefings and training signposting for investigators and research teams across both organisations
- Study-specific advice and support for hosted and JCRO-sponsored CTIMPs
- Liaison with external sponsors, CTUs, and partner organisations where required
Actions required
| 1 |
Review your CTIMP portfolio
Identify any studies likely to require documentation updates or protocol amendments.
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| 2 |
Check your GCP training status
Schedule a refresher if your training is more than 2 years old.
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| 3 |
Look out for JCRO communications
Updated templates, SOPs and transition timelines will be issued by the JCRO R&D.
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Non-CTIMP changes
Overview
From 28 April 2026, the HRA — working with all four UK nations — has introduced process changes to how non-CTIMPs are managed and reviewed. These apply across England, Wales, Scotland and Northern Ireland.
Non-CTIMPs cover clinical trials that do not investigate the safety and efficacy of a medicinal product — including trials of medical devices, surgical techniques, public health measures, and behavioural therapies, as well as other health and social care research.
Importantly, these are not legal changes. They are policy-level updates designed to align non-CTIMP processes more closely with the updated CTIMP regulations, improve consistency across all UK clinical research, and promote transparency and patient safety.
At a glance: Non-CTIMP key changes
Non-CTIMP key changes
| Terminology update | Initial approvals process | Modification process | Transparency and registration |
| "Amendments" become "Modifications" |
Clearer timelines for REC review |
Replaces "substantial amendment" process |
Aligned with CTIMP requirements |
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Applies to all approved non-CTIMP studies.
Three categories now apply:
- Substantial modification
- Modification of an important detail
- Minor modification.
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Validation confirmed within 7 calendar days.
Initial REC review completed within 30 days.
RFI response window: 60 calendar days.
REC responds to RFI within 10 calendar days.
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Validation within 7 calendar days.
Outcome issued within 35 calendar days.
RFI window: 60 days (extensions available).
Modified amendments no longer permitted.
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Register before first participant or within 90 days of approval (whichever is earlier).
Deferral period: 30 months from end of trial.
Plain language summary required in final report.
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| All UK nations. Not legally enforceable |
All UK nations. Not legally enforceable |
All UK nations. Not legally enforceable |
All UK nations. Not legally enforceable |
Browse the sections below to find out more.
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From 28 April 2026, the term 'amendment' will no longer be used for changes to approved non-CTIMP studies. All changes will be referred to as 'modifications', consistent with CTIMP terminology.
Note: Research Tissue Banks (RTBs) and Research Databases (RDBs) are excluded — the 'Notice of Substantial Amendment' form and the Amendment tab in IRAS continue to apply for these.
Three categories of modification now apply:
Modification categories
| Substantial modification |
A change likely to have a substantial impact on participant safety or rights, or on data reliability. Requires REC review. Examples include: significant changes to participant information sheets or consent procedures; change of chief investigator; change of primary endpoints; addition of a study arm; withdrawal of an independent data monitoring committee. |
| Modification of an important detail |
A change that does not significantly impact participant safety or rights, but which the REC needs to be made aware of for administrative or oversight purposes. Not reviewed by the REC — no outcome is issued. Examples include: changes to project title or contact details; increase in study duration (without extending treatment exposure); change of sponsor. |
| Minor modification |
Changes that do not fall into either category above. Can be implemented at any time without informing the REC (though other approvals such as HRA Approval may still be required). Examples include: addition of a new site or investigator; minor protocol corrections; changes in logistical or technical arrangements. |
Sponsor responsibility: Determining whether a proposed change is significant or insignificant remains the responsibility of the sponsor, consistent with current practice.
The application, booking, and REC meeting process for non-CTIMPs remains unchanged. However, the HRA has provided greater clarity on timelines for each stage:
Approvales process
| Validation |
REC aims to confirm validity within 1 working day. Sponsors have 7 calendar days to resolve issues. All submissions confirmed valid or invalid within 7 calendar days. |
| Initial REC review |
Completed within a maximum of 30 calendar days of validation. Applies to full committee reviews; Proportionate Review studies follow the same timeline via sub-committee. |
| Request for further information (RFI) |
Issued if the REC cannot give a favourable opinion after initial review. Sponsors have up to 60 calendar days to respond. Extensions can be requested directly from the REC. |
| REC response to RFI |
Outcome issued within 10 calendar days of receipt of a complete response. Possible outcomes: favourable opinion; favourable opinion subject to conditions; unfavourable opinion. |
| Appeal |
Unfavourable opinions can be appealed to appeals@hra.nhs.uk within 28 calendar days of receiving the outcome. |
From 28 April 2026, substantial modification requests follow a revised review process with defined timelines. The previous option to submit a 'modified amendment' following an unfavourable opinion no longer exists — sponsors now have the opportunity to respond to a Request for Further Information before a final decision is made.
Modification proecss
| Validation |
Confirmed within 7 calendar days. Sponsors have 7 days to resolve issues; failure to do so requires resubmission. |
| REC review |
Outcome issued within 35 calendar days of validation. Possible outcomes: favourable opinion; favourable opinion subject to conditions; RFI; unfavourable opinion. |
| Request for further information |
Issued within the 35-day window where the REC cannot approve outright. Sponsors have up to 60 calendar days to respond. Extensions are available on request to the REC. |
| REC response to RFI |
Outcome within 10 calendar days of a complete response. Modified amendments must not be submitted — the RFI process replaces this route. |
| Appeal |
Unfavourable opinions may be appealed to appeals@hra.nhs.uk within 28 calendar days. |
Transparency requirements for non-CTIMP clinical trials have been updated to align more closely with the new CTIMP registration rules, supporting consistency across all UK trials.
Research transparency and registration requirements
| Registration timing |
Non-CTIMP clinical trials must now register before the first participant is recruited, or within 90 days of approval — whichever is earlier. The previous 6-week post-recruitment window has been removed. |
| Deferral period |
Where deferral from registration is granted, this will be for 30 months from the end of trial date. If the end of trial date changes, the deferral period updates accordingly. |
| Plan language summary |
Summary A plain language summary of findings must be submitted as part of the Final Report. These are published on the HRA website alongside the research summary record. |
| Results sharing |
Sponsors are expected to make trial information publicly available and to offer to share results with participants, consistent with existing REC conditions. |
What you need to do now: Non-CTIMPS
| 1 |
Familiarise yourself with the new modification categories
Understand whether proposed changes to your study are substantial modifications, modifications of an important detail, or minor modifications. Use the IRAS Modification Tool to help categorise.
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| 2 |
Check registration status and timing
Ensure any non-CTIMP clinical trials in your portfolio are registered — or have a valid deferral — consistent with the new requirement to register before first recruitment or within 90 days of approval.
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| 3 |
Update study documentation language
References to 'amendments' in SOPs, templates, and correspondence should be updated to 'modifications' where applicable.
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| 4 |
Plan for the plain language summary
Ensure your study team is aware that a plain language summary of findings is required at the Final Report stage.
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| 5 |
Contact the JCRO if unsure
If you are uncertain how these changes apply to a specific study, contact the JCRO Research Governance & Sponsorship team for guidance.
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Need support?
Contact the JCRO Research Governance and Sponsorship Team on researchgovernance@sgul.ac.uk.