RECOMMENDATION PAPER ON DECENTRALISED ELEMENTS IN CLINICAL TRIALS
Recommendation paper DCT, V02, 1 October 2025 1
Version 02, 1 October 2025
Document history and effective date:
Date of endorsement by CTAG 15 October 2025
Supersedes: Version December 2022
Changes compared to superseded version:
- Front page includes a statement about cross- border trials with decentralised elements
- The national provision overview has been updated
Date come into effect Date of publication 29 October 2025
Important notice: The views expressed in this recommendation paper on decentralised elements
in clinical trials in the European Union/European Economic Area are not legally binding. Ultimately,
only the European Court of Justice can give an authoritative interpretation of Community law.
This recommendation paper is restricted to decentralised elements in general. For cross-border trials
with decentralised elements, it is the responsibility of the sponsor to check the national requirements
for cross-border trials and contact the national contact point of the Member State if authorisation of
the clinical trial is needed in home country of trial participant.
Recommendation paper DCT, V02, 1 October 2025 2
Recommendation paper on decentralised elements in clinical trials
TABLE OF CONTENT
ABBREVATION LIST ............................................................................................................. 3
1. INTRODUCTION, SCOPE AND GENERAL CONSIDERATIONS .............................................. 4
General considerations ................................................................................................ 5
2. CLINICAL TRIAL OVERSIGHT: ROLES AND RESPONSIBILITIES ......................................... 8
Considerations on responsibilities ................................................................................. 8
Considerations on keeping oversight on incoming data .................................................... 9
3. INFORMED CONSENT PROCESS ................................................................................. 11
Informed consent interview ....................................................................................... 11
Digital information leaflet .......................................................................................... 12
Informed consent signature ....................................................................................... 12
4. DELIVERY OF INVESTIGATIONAL MEDICINAL PRODUCTS AND ADMINISTRATION AT HOME14
Considerations on IMP delivery direct to trial participants .............................................. 14
Considerations on IMP storage and administration at the trial participant’s home ............. 15
5. TRIAL RELATED PROCEDURES AT HOME ..................................................................... 17
6. DATA COLLECTION AND MANAGEMENT INCL. DEFINING AND HANDLING SOURCE DATA .. 18
7. TRIAL MONITORING ................................................................................................. 19
APPENDIX: NATIONAL PROVISIONS OVERVIEW .................................................................... 20
Recommendation paper DCT, V02, 1 October 2025 3
ABBREVATION LIST
AE Adverse Event
CRF Case Report Form
CTCG Clinical Trial Coordination Group
CTEG Clinical Trial Expert Group
CTR Clinical Trial Regulation
EC European Commission
EEA European Economic Area
EMA European Medicines Agency
EMRN European Medicines Regulatory Network
ePRO Electronic Patient Reported Outcome
EU European Union
GCP Good Clinical Practice
GDP Good Distribution Practice
GMP Good Manufacturing Practice
GDPR General Data Protection Regulation
HMA Heads of Medicine Agencies
ICH International Council for Harmonisation of Technical Requirements
for Pharmaceuticals for Human Use
IMP Investigational Medicinal Product
IT Information Technology
IVD In Vitro Diagnostic
IVDR In Vitro Diagnostics Regulation
IWG Inspector Working Group
MDR Medical Device Regulation
MS Member State
SAE Serious Adverse Event
SAWP Scientific Advice Working Party
SNSA Simultaneous National Scientific Advice
Recommendation paper DCT, V02, 1 October 2025 4
1. INTRODUCTION, SCOPE AND GENERAL CONSIDERATIONS
Clinical trials on Investigational Medicinal Products (IMPs) are increasingly using procedures
conducted outside the traditional ‘clinical trial site’, a concept usually referred to as
decentralisation. In addition, there is increasing use of digital tools within clinical trials. The
COVID-19 pandemic highlighted the importance and usefulness of digital tools and decentralised
procedures in a healthcare setting and in clinical trials. The guidance on the management of
clinical trials during COVID-19 pandemic provided a set of recommendations that included
adjustments to the informed consent process, the distribution of IMPs and in monitoring under
specific circumstances. This guidance is specific to the COVID-19 health crisis in the European
Union (EU)/European Economic Area (EEA) and is intended to be revoked when there is a
consensus that the period of the COVID-19 outbreak in the EU/EEA has passed.
The above context and trend highlight the need to provide further recommendations on the
introduction of decentralised elements in the conduct of clinical trials in the EU/EEA, regardless of
any health crisis, and in consideration of the currently limited national guidances. The aim of this
recommendation paper is to address this requirement. The intention is to facilitate the use of
decentralised elements in clinical trials in the EU/EEA. However, the necessary level of trial
participant’s safety, protection of their rights and dignity should be ensured. In addition, the
reliability of data for publication and submission for regulatory decision-making should be
guaranteed.
It is acknowledged that certain decentralised elements in clinical trials have been adopted for
some time and that not all of these elements are likely to have a significant impact on scientific
validity, data integrity, benefit-risk ratio or the protection of trial participants’ rights. If a
decentralised element has been identified as a critical-to-quality factor as defined in International
Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH) E8,
a risk-proportionate approach should be followed and adapted to the risk of trial participants, trial
integrity of the research carried out and to the risk related to reliability of trial results. This is in
line with the Recommendations on risk proportionate approaches in clinical trials from the expert
group on clinical trials for the implementation of Regulation (EU) No 536/2014.
The recommendation paper will address the roles and responsibilities of the sponsor and
investigator, electronic informed consent, IMP delivery, trial related procedures at home, data
management and monitoring in a decentralised clinical trial setting. An overview of the current
national provisions applicable in each Member State in relation to these topics is outlined in the
appendix. It should be noted that the national provision appendix is for guidance purposes only as
it is not feasible to give a complete overview of all scenarios for implementing decentralised
elements in a clinical trial. It is at the discretion of the Member State involved in the assessment of
a clinical trial whether the use of certain decentralised elements is acceptable in a specific clinical
trial. Sponsors are encouraged to seek scientific advice via the European Medicine Agency [EMA,
scientific advice working party (SAWP)], or via national competent authorities [national or
simultaneous national scientific advice (SNSA)] regarding the use of specific decentralised
elements, especially on decentralised elements where experience and the evidence of their impact
may be limited. Sponsors may also request a consolidated opinion via the Clinical Trial
Coordination Group (CTCG) for regulatory issues of general impact not related to a specific trial.
This recommendation paper was created as part of the priority action 8 ‘Methodology guidances’ of
the ACT EU initiative of the European Commission (EC), the Heads of Medicines Agencies (HMA)
and the EMA. It was drafted in a collaboration between the HMA Clinical Trial Coordination Group
(CTCG), EC Clinical Trial Expert Group (CTEG) and the EMA GCP Inspectors Working Group (GCP-
IWG). It includes broad perspectives from the European medicines regulatory network (EMRN) as
well as perspectives by patient and health care professional representatives. Given the rapid
Recommendation paper DCT, V02, 1 October 2025 5
advances in the field of decentralised clinical trials, the paper is expected to evolve when new
insights and experiences are gained.
General considerations
Clinical trials with medicinal products have already adopted many decentralised elements such as
electronic diaries, wearables, phone calls and online appointments. How decentralised elements
are used in clinical trials depends on many factors including the type of clinical trial, the trial
population, the disease being treated, the condition of the trial participant, the type of medicinal
product, its characteristics and development stage. These elements should be considered
individually and in combination when planning for and implementing the use of decentralised
elements. In addition, the following general considerations should be taken into account:
• The rights, safety, dignity and well-being of the trial participants1 should be protected and
prevail over all other interests. The implementation of decentralised elements in the conduct of
a clinical trial should not result in increased risks to the safety, rights, and well-being of trial
participants. The appropriateness of decentralised elements depends in particular on (but not
limited to) the specific trial population, its disease, the type of assessment, the characteristics
of the investigational medicinal product(s), including its/their stage of development and thus
the current knowledge about its/their efficacy and safety profile.
▪ Adherence to EU and national applicable laws, regulations and established standards and
guidances for clinical trials (e.g. Clinical Trial Regulation: CTR EU no 536/2014, ICH E6, ICH E8,
applicable Good Manufacturing Practice (GMP) provisions, applicable Good Distribution Practice
(GDP) principles) and international ethical and scientific principles of medical research (e.g.
Declaration of Helsinki) is required for all clinical trials regardless the use of decentralised
elements. Particular emphasis should be placed on compliance with the General Data Protection
Regulation (GDPR EU no 2016/679).
• Sponsors and investigators should engage potential trial participants, patients or patient
organisations in a meaningful participatory process that involves them in an early and sustained
manner in the design, development and implementation of the clinical trial. Early participant
involvement in the design of the clinical trial is likely to increase scientific value. It may help
develop trust in the trial, facilitate recruitment, and promote adherence. Patients also provide
their perspective of living with a condition, which may contribute to the choice of decentralised
elements, for example, the feasibility of appointments by videoconference instead of a physical
visit, the use of digital tools, or the measurements of endpoints that are meaningful to patients
and selection of the appropriate population.
• When developing a clinical trial with decentralised elements, investigators/healthcare
professionals should be involved in the design, development, and implementation of the clinical
trial. The expertise of the investigators/health care professionals may contribute to ensure
clinically relevant objectives and endpoints, efficient safety monitoring and adequate medical
care. They can also contribute to identify the consequences of having less personal contact or
how to manage data collection and the quality and integrity of the (source) data.
• Any transfer of burden of trial related procedures to trial participants and/or investigators
should be weighed against the potential benefits of using decentralised elements in the clinical
trial. The sponsor may provide adequate support to trial participants and/or investigators to
facilitate the appropriate conduct of their tasks.
1 Where patient/trial participant is mentioned in the paper, relatives and/or legal representatives of
patient/trial participant are meant as well, whatever is applicable.
Recommendation paper DCT, V02, 1 October 2025 6
• For transparency reasons, and to facilitate the assessment of the clinical trial by authorities and
ethics committees, a summary of the decentralised elements planned in the clinical trial should
be provided in the cover letter of the clinical trial application.
• If it is determined that decentralised elements are likely to have a significant impact on
scientific validity, data integrity, benefit-risk ratio or impact on the protection of trial
participants’ rights, these should be considered in a specific and documented risk benefit
assessment. This risk benefit assessment as well as any risk mitigation action taken should be
clearly described in the clinical trial protocol or other protocol related document as part of the
clinical trial application to the Member State. This is required for any element impacting the risk
benefit assessment.
• In clinical trials with decentralised elements, parts of the clinical trial may be conducted outside
the traditional patient care centers, with the involvement of service providers. General medical
rules to protect patient’s/trial participant’s safety should be upheld in trials with decentralised
elements especially when patients/trial participants are separated from traditional patient care
centers. Among those is the assessment of individual patient’s risk profile, including appropriate
anamnestic information, physical examination and laboratory or imaging data by a responsible
investigator with the required trial population specific medical background. Exceptions should
be justified in the clinical trial application to ensure appropriate case-by-case review.
• The sponsor should provide in the clinical trial application a description of the funding of the
clinical trial and any other (financial) arrangements between funder, investigator and service
providers involved in the conduct of the clinical trial. Any conditions, such as economic interests
and institutional affiliations, that might influence the impartiality of the investigator should be
provided as well, as would be expected for any trial.
• Trials with decentralised elements should be designed to generate reliable and robust data.
Regarding regulatory decisions supporting marketing authorisation, the data is required to meet
the same expectations as those from trials with on-site procedures. Sponsors should carefully
discuss expected challenges prospectively and clarify how they plan to address potential
limitations introduced by decentralised elements in advance to ensure scientific quality of the
clinical trial. The following are examples:
o potential differences between the study population and target population which may
trigger discussion on the generalisability of the results (e.g. due to potential exclusion of
digitally illiterate persons or people who live in areas with limited internet connection).
o imposed modifications in outcome assessments which may trigger a discussion on their
validity (e.g, due to heterogeneous implementation of decentralised procedures across
clinical trials sites or among trial participants).
o the potential increase in missing data, overall or for specific endpoints. See also chapter 6
on data management.
These considerations are of utmost importance especially in trials identified as pivotal in
marketing authorisation applications. Sponsors are strongly encouraged to seek scientific
advice for these trials. In addition, qualification advice is encouraged when new methods or
endpoints are planned to be used.
• IT devices / technologies which are developed and utilised should be fit for the purpose of
reliable data collection and handling in accordance with the protocol. The use of computerised
systems and/or the creation/capture of electronic clinical data, should be compliant with the
‘Guideline on computerised systems and electronic data in clinical trials’2.
2 Guideline on computerised systems and electronic data in clinical trials, EMA, GCP IWG, 2023
Recommendation paper DCT, V02, 1 October 2025 7
• A contingency plan should be in place to minimise the impact of any risk, for example
malfunction of a digital tool or disruption of a planned decentralised visit, for identified critical-
to-quality decentralised elements.
• When medical devices, including in-vitro diagnostics (IVDs), are used in the clinical trial, their
use should be compliant with the applicable medical device legislation, such as the Medical
Device Regulation (MDR) EU no 2017/745, the In Vitro Diagnostic Directive 98/79/EC and/or
the In Vitro Diagnostic Regulation (IVDR) EU no 2017/746.
The following chapters outline more specific considerations regarding the decentralisation of
certain clinical trial aspects.
Recommendation paper DCT, V02, 1 October 2025 8
2. CLINICAL TRIAL OVERSIGHT: ROLES AND RESPONSIBILITIES
When parts of the clinical trial are conducted off-site, and when additional service providers such
as home nurses or providers of technology become involved, it is essential that the specific roles
and responsibilities of the sponsor, investigator, and any additional parties are clearly defined and
understood prior to the start of the trial. In addition, when trial participants are visiting the clinical
trial site less frequently, alternate methods of clinical monitoring of the trial participants’ current
health status and related data collection may need to be utilised. Data may be received from
different routes, for example collected at home by the participants themselves, by visiting
(external) healthcare professionals, or by digital tools. This poses a challenge to the oversight on
the rights, safety, dignity and well-being of the trial participants as well as the reliability of trial
results. As a general concept, introducing decentralised elements should be considered as an
extension of the clinical trial site with the inclusion of the trial participants’ home, resulting in an
additional obligation of oversight for investigators and sponsors. It is therefore important that,
when decentralised elements are implemented, it is ensured that the investigator and sponsor still
can fulfil their legal obligations as laid down in the CTR and ICH E6. In addition, with a potential
increase in the number of parties involved in the clinical trial, adherence to the GDPR needs to be
safeguarded.
The protocol should reflect that the sponsor and the investigator are in full control of their
respective areas of responsibilities at all times, e.g. with respect to the data processing, the
communication flow, and ultimately the rights, safety, dignity and well-being of the trial
participants and reliability of the trial data. In this section considerations in relation to investigator
and sponsor oversight are outlined.
Considerations on responsibilities
• Notwithstanding the potential involvement of additional service providers, the clinical trial
specific tasks as described in the protocol are ultimately the responsibility of either the
investigator or the sponsor, in accordance with ICH E6. Great care should be taken that the
delegation of tasks to the different parties is well defined. The introduction of decentralised
elements in a clinical trial may have a relevant impact in the trial conduct, therefore, it should
be clearly documented which tasks are conducted when, by whom, and in which setting (e.g. at
the clinical site, at the trial participant’s home, etc.), and how the required oversight by the
sponsor and/or supervision by the investigator is achieved. The general overview of the
workflow of these different tasks and actions to be taken within the trial should be described in
the protocol, and in more detail in a protocol related document.
• In case service providers have been delegated trial specific tasks, a corresponding rationale and
the extent of their involvement should be described in a high level in the protocol, and in detail
in a protocol related document. The investigator retains the ultimate responsibility for tasks
involving trial related medical decisions (i.e. trial participant eligibility and enrolment, protocol
specified medical procedures, changes in medication, etc.) and for the rights, safety, dignity
and well-being of the trial participants. See also the appendix for current national provisions
regarding the involvement of external health care providers.
• Any trial specific task that is delegated to a service provider should be specified in a written
agreement between the responsible party for the task (according to ICH E6) and the service
provider (see also the EMA GCP IWG Q&A B.2, and B.8). When the sponsor selects a service
provider and the investigator is not involved in the contractual arrangement with this service
provider, the contract between the sponsor and the investigator should clearly document the
contractual arrangements with the service provider if it concerns tasks under investigator’s
Recommendation paper DCT, V02, 1 October 2025 9
responsibility. This allows the investigator to agree or not to the deployment of service
providers for certain trial specific tasks related to the medical care of trial participants. As
stated previously, in the general considerations of this paper, it is recommended that the
investigator should be involved in an early stage when designing the decentralised elements in
the clinical trial. In this way it can be assessed early on what are the needs of the investigator
with regard to the use of service providers for trial specific tasks that fall under the
responsibility of the investigator.
• The sponsor should ensure that the contracted service provider is qualified and experienced in
the tasks they conduct for the trial. This should be reflected in the contract between the
sponsor and the investigator, in order that the investigator is aware of, and can agree or not
with the qualification of the service provider when the delegated tasks lie within the
investigator’s responsibility. The investigator should have the possibility to ask for any
additional information in order to perform due diligence and to require any change to the
agreement or to the service when considered necessary, including the possibility to reject a
certain service provider.
It is the investigator’s responsibility to ensure that the service provider is properly trained on
the trial specific tasks they have to conduct, when these tasks concern the medical care of the
trial participants or lie within the investigator’s responsibility.
• To maintain the investigator’s responsibility regarding the medical care and safety of the trial
participant and to ensure that the sponsor has adequate oversight over the conduct of the
clinical trial effective lines of communication should be established, documented and shared
with all relevant parties, including trial participants, investigators, sponsor and any service
providers. All parties involved should have access to the information required to fulfil their roles
and responsibilities related to the conduct of the clinical trial at any time. In case of an
emergency, an effective communication plan needs to be in place, so that all relevant parties
can act without undue delay. The trial participant should be well informed and receive contact
details for all necessary situations including who to contact for acute cases, but also for device
failures, questions on home visits, etc.
Considerations on keeping oversight on incoming data
• Trial participants, investigators and service providers involved in the trial should receive
training on how to use the digital tools employed in the trial, to ensure proper data collection,
review, and transmission. In addition, the trial participants and service providers should receive
training on what is considered an (serious) adverse event ((S)AE), who they should report this
to, in what timeframe, and how to manage the (S)AE.
• When AEs are reported via several routes (digital tool, external healthcare professional, or trial
participant) it is important that procedures are in place to identify potential duplicates.
• The use of digital tools (such as wearables) result in an increase in the amount of incoming
data. This may challenge the capacity of the investigators to fulfil their responsibilities.
Emerging data could be continuously at hand, and a clear procedure should be in place to
determine how to handle this constant flow of information. The review frequency of the
incoming data by the investigator should be based on the relevance of the data to the safety
and well-being of the trial participant, and the relevance of the data for the efficacy.
The review of safety data should be planned with a risk-based perspective, which may include
the IMP safety profile, the indication, known potential risks, the use of notifications and alerts.
Recommendation paper DCT, V02, 1 October 2025 10
The priority is to capture and assess SAEs in a timely manner, without creating an unacceptable
burden for the investigator and/or the trial participant. The use of notifications and alerts is
recommended to ensure timely assessment of SAE related data. In designing a trial with digital
tools, the sponsor and investigator should anticipate what kind of safety alerts may occur and
specify in the protocol how these alerts will be handled. If it is foreseen that a digital tool may
generate critical safety data that needs immediate medical attention, a plan should be in place
describing this. It should be outlined in the protocol how the investigator and/or the service
provider should manage these situations, what actions should be taken and by whom. A
schematic overview of parties involved, information flow and respective duties is recommended.
The trial participant should be informed what to expect and what actions they may need to
follow in these situations. In addition, a participant targeted scheme of the duties and
information flow with the parties involved might enhance understanding.
• The sponsor should ensure that digital tools are transmitting the required alerts as planned.
The tool that generates alerts to the investigator should be validated. A risk mitigation plan
should be in place for times that the tool may not work as intended.
• The trial participant should be fully informed in advance on how the information transmitted via
digital tools, for example electronic Patient Reported Outcomes (ePROs), will be acted upon. It
should be made clear to the trial participant that the investigator may not review such data in
real time, and that if the trial participant experiences any specific safety concern they need to
directly contact the investigator to report such an issue.
Recommendation paper DCT, V02, 1 October 2025 11
3. INFORMED CONSENT PROCESS
An important aspect of a clinical trial is that the potential trial participants give their voluntarily
informed consent to participate. To give consent, the potential participant needs adequate
information. Informed consent is not only of ethical and legal importance: good communication
between the investigator and the trial participant is beneficial for mutual trust and may promote
trial compliance. Therefore, when considering the appropriateness of conducting the informed
consent process in a remote manner, to use digital information leaflets, and/or to use electronic
methods for the signature of the informed consent form, several aspects have to be thoroughly
assessed. These include the design of the clinical trial, the characteristics of the trial population,
and the risks, burdens and potential benefit related to participating in the clinical trial.
The entire procedure for obtaining informed consent, i.e. the selection, the evaluation of the
eligibility, and the actual informed consent process, should be described step-by-step in the clinical
trial application to ensure appropriate ethical review. The rationale for not having a physical
examination as part of this procedure should be given in the protocol or other protocol related
document. The sponsor should also describe in the protocol the chosen method for obtaining
informed consent.
Regardless if only a part of or the whole informed consent process is conducted remotely, the
process should still be carried out in compliance with the principles laid down in the CTR, ICH E6,
the GDPR and national legislation.
The informed consent process should be documented in a manner that allows verification of the
receipt of information by the trial participant, the discussion between the person qualified to
obtain the consent and the trial participant, as well as giving of the consent.
Informed consent interview ICH E6 requires that all potential trial participants are fully informed on the clinical trial and are
given the opportunity to ask questions. In general, this should be a physical meeting between the
investigator and the potential trial participant. However, in some cases it can be justified that this
is done remotely. The more vulnerable the trial population, the more limited the current
knowledge of the efficacy and safety profile of the IMP(s), the more complex the trial concept and
the higher the risks associated with the trial-specific interventions, the more necessary is a
physical meeting between trial participant and investigator for the purpose of informed consent.
In case the potential trial participant is not visiting the clinical trial site, the following aspects
should be considered and addressed in the clinical trial application:
• As part of the process of obtaining informed consent, it is considered essential that face-to-
face communication takes place between the potential trial participant and the investigator, or
a qualified person designated by the investigator. If this discussion is done in a digital/virtual
meeting, it is recommended that this takes place in real time where the parties can both see
and communicate with each other via audio and video. The remote face-to-face contact should
allow for asking questions and the investigator should make every effort to check the identity
of the participant if they are not already known by them, and conversely, the participant
should have the right to ask for proof of the investigator’s identity if they have not been in
contact before. Deviation from (remote) face-to-face communication should be justified in the
clinical trial application, together with a description of how the verification of the identity of
the investigator and the trial participant will be performed in such cases, and how it will be
determined that the trial participant has understood the information. See also the appendix
for the current national provisions.
• The sponsor should ensure that trial participants and investigators are given the option to
Recommendation paper DCT, V02, 1 October 2025 12
have the informed consent interview on site if this is preferred by the trial participant or the
investigator. However, in duly justified cases only the remote option may be offered.
• Individual participant related factors affecting the use of decentralised elements of the clinical
trial should be evaluated by the investigator during the informed consent interview.
• The reliability and confidentiality of the method used should be ensured. As a general
principle, the communication channel used for the informed consent interview should be
encrypted to protect the confidential information that will be discussed.
Digital information leaflet • The use of different kinds of media may enhance the trial participant’s comprehension of the
trial. However, when considering the use of electronic methods, the sponsor should also be
aware that its use may unintentionally discriminate against participants who cannot or prefer
not to use such technology. Alternative methods for the electronic provision of information
should be available. There may be exceptions where the sponsor only provides a digital
information leaflet. In such circumstances, this should be described in the protocol and
justified in the clinical trial application.
• The sponsor is responsible to verify whether a clinical trial site and/or the data protection
officer of that site agrees to the use and storage of electronic methods for the consent
process.
• It should be ensured that the information provided to the trial participant is in a form that can
be stored and retrieved by the trial participant.
Informed consent signature • There are various ways of obtaining a signed informed consent form by remote means. This
includes for example a paper consent form sent to the participant signed with a ‘wet ink
signature’ and sent back by post, or a digital consent form signed with an electronic signature,
i.e. completely digital.
Regardless of the format of the informed consent, the method should allow reconstruction of
the process, including the validity of the signatures. The sponsor should ensure that the
systems used have proportionate security levels and that safeguards regarding confidentiality
are in place. In general, the electronic signature functionality should be in accordance with the
requirements described in the ‘Guideline on computerised systems and electronic data in
clinical trials’ 3.
In addition, the method used to record informed consent should follow national requirements
with regards to acceptability of electronic signatures (see appendix for current national
provisions).
• When using electronic methods, the trial participants should be able to download an electronic
copy of the signed and dated informed consent form, or to receive a print-out of the electronic
copy. If an electronic copy, it should be protected against modification; any modification
should invalidate the signatures.
• Existing procedures related to re-consent should be adapted to the use of electronically signed
• Procedures should be in place to handle follow-up steps after the consent has been withdrawn
3 Guideline on computerised systems and electronic data in clinical trials, EMA, GCP IWG, 2023
Recommendation paper DCT, V02, 1 October 2025 13
electronically, including partial withdrawal and complete withdrawal, due to the impact on
patient participation and data collection. These procedures should include timely notification to
the investigator and a communication plan with all other stakeholders. By any means,
withdrawals should also be possible outside of the system, and this should be recorded by the
investigator.
Recommendation paper DCT, V02, 1 October 2025 14
4. DELIVERY OF INVESTIGATIONAL MEDICINAL PRODUCTS AND ADMINISTRATION AT
HOME
Where it is intended for the IMP4 to be delivered and/or administered at the trial participant’s
home, a risk assessment should be completed to determine if such an approach is appropriate.
The risk assessment should at a minimum take into account the following aspects: the knowledge
and uncertainty of the IMP and its safety profile, the route of administration, the trial population,
whether an observation period is required, the need for emergency plans, the preparation of the
final IMP for administration, its stability, the storage conditions, and the robustness of IMP delivery
logistics (the risk of an inadvertently IMP delivery to a non-intended recipient).
The CTR aims to harmonise the rules of the conduct of clinical trials in the member states, while
setting high standards of quality and safety of IMPs to ensure the protection of public health.
Therefore, the import of IMPs into the EU requires an authorisation (CTR article 61), and the
applicable principles of GDP should be considered in the logistics of IMPs. Shipping and the
contractual agreements regarding IMP shipment between sponsor and investigator site or
pharmacy are covered by the ‘Guideline on the responsibilities of the sponsor with regard to
handling and shipping of investigational medicinal products for human use in accordance with
Good Clinical Practice and Good Manufacturing Practice’. IMP delivery to the trial participant is not,
however, within the scope of that guideline.
In this section considerations are given concerning the delivery of the IMP and the administration
at the trial participant’s home.
Considerations on IMP delivery direct to trial participants • If the IMP is not dispensed to the trial participant by the investigator or delegated healthcare
professional at the site, it is recommended that the vendors responsible for delivery to the
participant are authorised to distribute or dispense medicinal products as much as possible. Any
non-authorised vendor used in the logistics should be qualified and supervised by the
authorisation holder, in accordance with the principles of GDP. There must be a written contract
which clearly establishes the duties of each party. It is recommended that the number of
separate transportation steps are minimised.
• The investigator remains responsible for the decision of treatment which should be documented
(for example prescription or Interactive Response Technology system) prior to any delivery of
IMP to the trial participant’s home. Delivery to the participant’s home could mean another
suitable address the participant prefers to receive the IMP at, provided that:
o regulatory requirements are complied with;
o risks of exposure to conditions that could impact quality and integrity of the product are
minimised;
o the applicable principles of the guidelines on GDP of medicinal products for human use are
taken into consideration.
When the given address is abroad, it should be verified whether the national legislation of that
country allows the IMP to be delivered there (see appendix on national provisions). The given
address should also be the place where the IMP is stored and administered, to avoid additional
transport by the trial participant themselves.
• There are several options for delivery of the IMP to the trial participant’s home, depending on
what is permitted by national requirements. This can include delivery from the pharmacy of the
investigator site, from a delegated pharmacy, or from a depot. The sponsor has the overall
4 The recommendations for IMP delivery and administration at home also apply to auxiliary medicinal products (AxMP).
Recommendation paper DCT, V02, 1 October 2025 15
responsibility for the process and the contracts or agreements, which should reflect the
principal investigator’s responsibilities pursuant to ICH E6. Please refer to the appendix for the
acceptable options in the member states regarding the delivery of the IMP to the trial
participant’s home. The arrangements for delivery of the IMP to the trial participant should be
described in the clinical trial protocol or the Investigational Medicinal Product Dossier.
• The sponsor should ensure that the personal data of the trial participants required for the
delivery of the IMP is used in accordance with the GDPR on a need-to-know basis. For example,
it should be ensured that personal data is solely accessible to those involved in the delivery of
the IMP and will not be stored for other purposes than the delivery of the IMP. Access to the
personal data should be restricted as soon as the final delivery is completed. Information
should be made available only for the purpose of monitoring, auditing, inspections, and to trial
participants for the exercise of their GDPR rights.
• Trial participants should be made aware during the informed consent process that their contact
details will be used for delivery purposes if the IMP is to be delivered to the trial participant’s
home. Details regarding the use of contact information should be outlined in the participant
• When delivering the IMP, it should only be handed over to the trial participant (or a
representative, if applicable), or the present health care professional involved in the clinical
trial. Sponsor procedures should be in place covering delivery and receipt of the IMP. With
regard to receipt of IMP, the procedure should detail the steps and responsibilities in relation to
confirmation of IMP identity (e.g. batch number) to ensure that what has been dispatched has
actually been delivered. In some cases, the trial participant (or a representative) may not be
available to accept and sign the receipt of the IMP. In this case, the IMP should be brought back
by the service provider to the original location (investigator’s site, (central) pharmacy, or
depot).
• As an alternative to delivering the IMP to the trial participant’s home, the IMP could be
dispensed by local pharmacies (based on a prescription issued by the investigator), provided
that the labelling requirements in the CTR are fulfilled, and if national requirements allow (see
appendix). In particular, sponsors are reminded to consult Article 61(5) of CTR regarding
labelling requirements. The local pharmacy should be aware that the prescription of the IMP is
in the context of a clinical trial, and if necessary, be trained to dispense the IMP.
Considerations on IMP storage and administration at the trial participant’s home • The sponsor and the investigator should consider during the planning stage of the clinical trial
how the appropriate storage conditions of the IMP can be met, and whether the IMP is suitable
for administration at home. The inclusion/exclusion criteria should include provisions related to
the adequacy of the trial participant’s home for storage of the IMP, such as temperature control
and restricted access where necessary. Sponsors may consider providing trial participants
additional equipment necessary for IMP storage. This should be described in the protocol or
other protocol related document (e.g. pharmacy manual), including the documentation
provided to participants. The investigator should give instructions to the trial participants on the
use and storage of the IMP. The instructions should be realistic, feasible and the additional
burden for the trial participant should be part of the aforementioned risk assessment.
• The investigator and the sponsor should consider whether administration at home can be done
by the trial participants themselves or if a trained, experienced and qualified healthcare
professional is required for administration. In the case of complex administrations, special
preparation or handling requirements, or when required by the safety profile of the IMP (e.g.
unknown or potential serious adverse events in connection to the administration), health care
professionals should always be involved.
Recommendation paper DCT, V02, 1 October 2025 16
• Generally, if an IMP is required to be administered by a healthcare professional, shipping
directly to the trial participant may not be appropriate. In the event it is required for IMP to be
shipped directly to the trial participant separately, clear instructions for storage of the IMP prior
to healthcare professional visit should be given, as well as a clear explanation that the IMP is
not to be administrated before the visit of the healthcare professional nor before the
investigator’s decision.
• If it is anticipated that the trial participants will prepare and administer the IMP as outlined in
the protocol, they should be instructed in advance about these aspects. Where appropriate,
there should be instructions provided regarding these steps as well as dosing, in addition to
what is already present on the IMP label or package leaflet. These instructions should be
adapted to the needs of the individual trial participants. The use of electronic step-by-step
instructions which are easily and promptly accessible (such as QR code scanning), could be
considered. Depending on the safety profile of the IMP, the investigator should contact the trial
participants after the first delivery of the IMP to ensure proper handling of the IMP. The sponsor
may consider providing additional equipment necessary for the safe administration, use and
destruction of the IMP to the trial participants, in which case this should be described in the
protocol or other protocol related document (e.g. pharmacy manual), including the
documentation provided to the participants.
• The investigator should follow-up, at regular intervals, with participants to ensure the IMP is
taken appropriately and according to the IMP instructions.
• Procedures should be in place for IMP accountability and treatment compliance of trial
participants. These tasks fall under the investigator’s responsibility according to ICH E6.
• Procedures should be in place for IMP return from the trial participant’s home, and destruction
of the unused IMPs, in compliance with the protocol and local safety requirements. The
procedure should also cover recalls during the conduct of the trial, and the steps taken to avoid
that the IMP remains at the trial participant’s home beyond the envisaged treatment period.
Recommendation paper DCT, V02, 1 October 2025 17
5. TRIAL RELATED PROCEDURES AT HOME
In a clinical trial with decentralised elements, trial related procedures may take place outside of
the clinical trial site, such as in the trial participant’s home5. These procedures could be performed
by the trial participant, the investigator staff visiting the trial participant at home, or a person
contracted for the trial and delegated to perform them. For these procedures or examinations
performed at home, considerations include, but may not be limited to the following:
• The investigator should ascertain whether the trial participant's home situation and premises
are suitable to have trial related procedures performed at home. It should be considered that
there may be personal/social circumstances which could exclude home visits.
• Inclusion/exclusion criteria should include provisions related to the adequacy of the trial
participant’s home for critical trial related procedures at home. The trial participant should be
informed during informed consent process about trial procedures planned to take place at
home.
• Performing trial-related procedures at home should only be done if the procedures do not
cause additional risk to trial participant or reliability of the data and the person performing the
task is qualified and/or trained to perform the task. For example, if biological samples are
collected at home, it should be considered whether persons taking the sample are qualified
and allowed by legislation to take the sample. In addition, adequate handling and storage
conditions for the samples throughout the entire process should be assured.
• In the event of trial participants performing trial related tasks it should be ensured that
appropriate training is provided to them, and any additional trial participant burden duly
considered, including tasks related to digital data collection.
• The sponsor and/or investigator should ensure that appropriate guidance and training is
provided to the delegated person(s) to conduct the tasks at home correctly.
• The insurance or indemnity or a guarantee or a similar arrangement foreseen by CTR should
be in place to cover any damage resulting from trial related procedures performed at home.
• The investigator should monitor compliance of the trial participant considering the lack
of/decrease in the number of face-to-face visits/meetings between the trial participant and the
investigator and/or delegated staff.
• The trial participants should be given the opportunity to visit the investigator in person if
needed/preferred and they should be able to have a direct contact line if further support to
perform a trial related task/collect data is needed.
• There should be procedures in place for reporting and management of adverse events noticed
by the trial participant or by any delegated person during home visits (see also chapter 2
about considerations on maintaining oversight on incoming safety data).
• The sponsor should provide alternatives if a trial participant is unable or not willing to use
her/his/their own private device (mobile phone, tablet, etc.) to capture trial data.
5 A trial participant’s home can be more than one home, e.g. children with parents that are separated.
Recommendation paper DCT, V02, 1 October 2025 18
6. DATA COLLECTION AND MANAGEMENT INCLUDING DEFINING AND HANDLING
SOURCE DATA
Decentralised clinical trials are characterized by an extensive shift of data collection from the
investigator/investigator site to the trial participants and/or their caregiver and/or service
providers (e.g. home nurses). Direct data capture by electronic systems (e.g. electronic Case
Report Forms (CRFs), ePROs, wearables etc.) may occur, for instance, at the clinical trial site or
off-site locations.
According to ICH E6, the data recorded during the clinical trial should be credible, reliable and
verifiable. In addition, the data protection requirements according to the GDPR should be adhered
to (see also chapter 1, general considerations).
Utilising multiple systems and parties adds complexity and requires an adequate oversight and
implementation of adequate measures by the sponsor. To this end, the sponsor should:
• Ensure that all parties involved in the clinical trial have an overview of the data flow; a data
flow diagram with additional explanations in the protocol is highly recommended.
• Ensure that the used data acquisition tools are configured and validated in accordance with
their intended use.
• Determine the type and scope of the trial participants’ personal data to be collected and
ensure adequate protection in compliance with the GDPR of such personal data in any step of
the process.
• Ensure that when source data captured by a data acquisition tool is transferred to another
location and subsequently irreversibly deleted from the data acquisition tool, both the data and
the metadata are transferred (see ICH E6 1.63 Certified Copy).
• Implement measures such as encryption to minimise the risk of unauthorised access, when
transferring the data from a data acquisition tool to a server.
• Ensure access to trial data is controlled by defined user rights and methods of access for all
relevant parties involved. Unauthorised access should be prevented using appropriate security
measurers e.g. firewalls.
• Ensure control of and continuous and complete access by the investigator to both source data
generated either on-site or off-site as well as source data reported to the sponsor (e.g. central
lab data).
The risk of erroneous data entry for data measured and entered directly by trial participants,
especially on primary, key-secondary or safety endpoints should be minimised by appropriate
Additional advice on elements specific to digital data capture systems can be found in the
‘Qualification opinion on eSource Direct Data Capture (DDC) (EMA/CHMP/SAWP/483349/2019)’
from the EMA Scientific Advice Working Party (SAWP) and the ‘Notice to sponsors on validation
and qualification of computerised systems used in clinical trials (EMA/INS/GCP/467532/2019)’. In
addition, reference is made to the EMA GCP matters Q&A B3 ‘How and where should source data
be defined’ as well as to the EMA GCP matters Q&A B5 ’What are the expectations of the
investigator’s copy of the CRF when using a web based application’.
Recommendation paper DCT, V02, 1 October 2025 19
7. TRIAL MONITORING
Trial monitoring is part of the quality control processes in clinical trials.
• As detailed in ICH E6, the monitoring strategy should be based on the specifics of a clinical
trial. These specifics may include, as applicable, decentralised processes and tools described in
the previous sections. For example, if according to the trial protocol, safety and/or efficacy
data are collected via ePRO or wearables, or if key processes (e.g. those related to primary
endpoints) are performed outside the investigator site (e.g. at central reading facilities, central
laboratories), the specific risks associated with these decentralised processes, tools, locations,
and individuals involved should be taken into account in the monitoring strategy.
• Monitoring procedures can be divided into centralised and site monitoring, and generally a
combination of them both is appropriate. Site monitoring is usually performed on-site.
Depending on its purpose and suitability it may be performed off-site (remotely).
• When establishing remote access for the purpose of monitoring, the principles of necessity and
proportionality should always be adhered to. The monitoring strategy chosen should not
unduly burden the site.
• If remote access to source data and documents is foreseen, additional measures with respect
to confidentiality of data access and security of the systems should be in place. Further
guidance on this is being drafted by the GCP IWG. See appendix with current national
provision overview per Member State whether remote access to medical records by the
monitor or auditor is allowed.
Recommendation paper DCT, V02, 1 October 2025 20
APPENDIX: NATIONAL PROVISIONS OVERVIEW
This overview of national provisions does not purport to be an interpretation of law and/or
regulations and is for guidance purposes only.
The answers to the questions stated in the national provision overview are giving by the individual
Member States and relates to the context and general recommendation as provided in the
recommendation paper. References for the relevant sections within the recommendation paper are
given in the question header.
Please note that footnotes from each Member State are given in the tables following the national
provision overview. The footnotes provide legislation reference, background or conditions for a ‘No’
or a ‘Yes’.
Recommendation paper DCT, V02, 1 October 2025 21
Please see relevant footnotes for responses marked with an asterisk. A footnote may be raised even though no response is given.
AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IS IT LI LT LU LV MT NL NO PL PT RO SE SI SK
The delivery of IMPs from sponsor/site, in relation to RP section 4.
Q1: Is it possible to deliver IMPs directly to trial participants from their associated trial site?
No *
No *
Yes *
No *
Yes *
Yes* Yes Yes * Yes *
Yes * No *
Yes Yes *
Yes Yes *
Yes *
Yes *
Yes *
Yes *
Yes Yes Yes *
Yes Yes *
No *
Yes
Q2: Is it possible to deliver IMPs directly to trial participants from the pharmacy associated with the trial site?
No *
No *
Yes *
No *
Yes *
Yes* Yes No *
* Yes *
Yes *
* No *
Yes Yes *
Yes No *
No *
Yes *
Yes *
Yes *
Yes Yes Yes *
No *
Yes *
* Yes
Q3: Is it possible to deliver IMPs directly to trial participants from any delegated pharmacy?
No *
No *
No No Yes *
Yes Yes *
No *
No *
No *
No *
Yes No *
Yes Yes *
Yes *
No *
No *
Yes *
No Yes *
Yes No *
Yes *
No *
Yes *
No *
Yes
Q4: Is it possible to deliver IMPs directly to trial participants from the IMP manufacturer with a MIA license?
No No *
No No No *
No * No *
No *
No *
No *
No *
No *
Yes No *
Yes *
No *
No Yes *
No No No *
No *
Yes *
No No No *
No
Q5: Is it possible to deliver IMPs directly to trial participants from the trial sponsor (sponsors intermediaries/depots)? If yes, footnote states if a licence is required for the depot to carry out this task and how to obtain this licence.
No No *
No No No *
No * No *
No *
No *
No *
No No *
No Yes *
Yes *
No No Yes *
No No No *
No *
No *
Yes *
No * No
The shipment of IMPs from sponsor/site across boarders within the EU, in relation
to RP section 4.
Q6: Is it possible to deliver IMPs directly to trial participants from e.g. distribution/manufacturing/pharmacy licence holders located in other EU MSs if legally allowed to carry out this task in the country of origin?
No *
No *
No No No *
No* Yes No *
No *
No *
No *
No *
No *
Yes Yes *
Yes *
No *
No Yes No No *
No *
No *
No *
Yes No *
No *
No
Q7: Is it possible to deliver IMPs directly to investigators from e.g. distribution/manufacturing/pharmacy licence holders located in other EU MSs if legally allowed to carry out this task in the country of origin?
Yes *
Yes *
No * Yes Yes* Yes Yes Yes *
No *
No *
Yes *
Yes *
Yes Yes *
* Yes No Yes Yes No *
No *
No *
Yes *
Yes No *
No *
Yes
Recommendation paper DCT, V02, 1 October 2025 22
Labelling of IMP, in relation to RP section 4.
Q8: Is it possible for any delegated pharmacy to label IMP or is this restricted to the pharmacy associated with the trial site?
No No *
No * Yes *
* Yes * Yes *
No *
No *
No *
Yes Yes *
Yes Yes *
No No * No *
No *
No No Yes *
* Yes
Recommendation paper DCT, V02, 1 October 2025 23
Please see relevant footnotes for responses marked with an asterisk. A footnote may be raised even though no response is given.
AT BE BG CY CZ DE DK EE EL ES FI FR HR HU IE IS IT LI LT LU LV MT NL NO PL PT RO SE SI SK
The shipment and hand-out of IMPs from pharmacies. This is currently not included
in the recommendation paper but may be relevant in next version of the RP.
Q9: Is it possible to deliver or dispense authorised IMPs directly to trial participants from pharmacies not associated with the clinical trial sites? This include authorised investigational medicinal products not used according to their SmPC.
Yes *
No *
No No No *
Yes Yes *
No *
No *
No *
No *
No *
No *
Yes Yes *
Yes *
No *
No Yes No Yes *
Yes *
No *
No *
No *
Yes *
* Yes *
Q10: Is it possible to deliver or dispense non-authorised IMPs directly to trial participants from pharmacies not associated with the clinical trial sites?
No No *
No No No *
Yes No* No *
No *
No *
No *
No *
No *
Yes No Yes *
No *
No No Yes *
Yes *
No *
No *
No *
Yes *
* Yes *
The eConsent process, in relation to RP section 3.
Q11: Is a physical face to face meeting between the trial participant and the PI or a member of the research team always mandatory during the consent procedure (even if the rest is conducted remotely)?
No No Yes *
Yes No *
Yes *
No* * * No *
No No *
Yes *
Yes *
No No *
No Yes No No No *
No No *
Yes *
No No * No
Q12: Is it possible to use electronic signatures instead of wet ink? If yes, please specify in the footnotes which eIDAS category is expected for the electronic signature.
Yes *
Yes *
Yes *
Yes Yes *
Yes *
Yes *
Yes *
* Yes *
Yes *
Yes *
Yes *
Yes *
Yes Yes *
Yes *
No Yes *
Yes Yes *
Yes *
Yes *
Yes *
Yes *
Yes *
* Yes *
Trial participant oversight and home visits, in relation to RP section 2 and 5.
Q13: Is it possible for the PI to delegate tasks under their responsibility to a qualified (for the delegated task) external healthcare provider?
Yes Yes *
Yes *
* Yes *
Yes *
Yes Yes *
Yes *
Yes *
Yes Yes *
Yes Yes *
Yes Yes Yes *
No Yes Yes Yes *
Yes *
Yes *
Yes *
Yes *
Yes *
Yes Yes
Q14: Certain tasks/procedures carried out at home may require supervision of the investigator (a physician). Is it allowed for the physician to supervise remotely?
Yes Yes *
Yes *
* No *
Yes *
Yes * * * Yes * Yes *
Yes *
Yes *
Yes Yes Yes *
* Yes Yes *
Yes Yes *
Yes *
No *
Yes *
* No
Recommendation paper DCT, V02, 1 October 2025 24
Trial Monitoring using remote access to source data, in relation to RP paper
section 7
Q15: Is remote access to the medical records allowed by the monitor or auditor?
Yes *
No *
Yes *
* Yes *
Yes *
Yes *
* No * Yes Yes *
No *
Yes *
Yes *
Yes *
Yes *
No * Yes Yes *
* * Yes *
No No No *
No
Recommendation paper DCT, V02, 1 October 2025 25
Footnotes to the DCT Provision Overview by Member States
BE
Q1 Not allowed currently, unless specified in the CTA why a waiver should be authorized, referring to the Q&A n°10: https://www.ema.europa.eu/en/human-regulatory/research-development/compliance/good-clinical-practice/qa-good-clinical- practice-gcp [Change in national legislation ongoing]
Q2 Same approach as in Q1 and according to the RD of 21 January 2009, a pharmacy in Belgium must deliver each medication in person to a patient, with the exception in art. 29 of medication free of prescription. [Change in national legislation ongoing]
Q3 According to the RD of 21 January 2009, a pharmacy in Belgium must deliver each medication in person to a patient, with the exception in art. 29 of medication free of prescription. [Change in national legislation ongoing]
Q4 According to the RD of 21 January 2009, a pharmacy in Belgium must deliver each medication in person to a patient, with the exception in art. 29 of medication free of prescription. An investigator can also provide the trial participant in person with an amount of medication (IMP). [Change in national legislation ongoing]
Q5 Same as Q4
Q6 Same as Q4
Q7 According to art. 43 of the RD 9/10/2017
Q8 Labelling is a manufacturing operation. Labelling is only possible if the site/pharmacy has a GMP licence.
Q9 Only a delegated pharmacy (delegated by the PI) can deliver or dispense IMPs.
Q10 Only a delegated pharmacy (delegated by the PI) can deliver or dispense IMPs.
Q11 -
Q12
According to the national guidance on e-ICF, for remote signing, only an advanced or a qualified electronic signature as defined in the eIDAS regulation (Ref. 3) should be used as they uniquely identify the individual signing. Only a qualified electronic signature has the equivalent legal effect of a handwritten signature (eIDAS, art 25. §2.). Signatures via e-ID (Ref. 4) or itsme® (Ref. 5) are qualified electronic signatures. The advanced signature should comply with the defined requirements as described in the article 26 of the eIDAS Regulation that give guarantees of the identification of the individual signing. More information is available on the website of the FPS Economy (Ref. 6). References are available in https://consultativebodies.health.belgium.be/en/e- ICF%20guidance%20Belgium_30-09-2020
Q13 Provided that the delegated tasks fall under the qualification of the study personnel according to the Belgian legislation.
Q14 Provided that the delegated tasks fall under the qualification of the study personnel according to the Belgian legislation.
Q15
Remote source data verification is as such not allowed. This is only possible in specific cases, approved during the CTA process under the following conditions: - An agreement has been setup describing rSDV which is approved by all parties (institution, principal investigator and the sponsor or the CRO assigned). - The rSDV can be organized by the investigator’s site and is therefore technically feasible without compromising the confidentiality of the Electronic Medical Records data.
AT
Q1 §57, §59(1), (9) AMG (Austrian Medicines Act) Change in national legislation/guidelines is ongoing
Q2 §57 AMG (Austrian Medicines Act), exception: Authorised or registered, non-prescription medicinal products could be delivered directly to patients as per §59(10) AMG (Austrian Medicines Act). Change in national legislation/guidelines is ongoing
Q3 §57 AMG (Austrian Medicines Act), exception: Authorised or registered, non-prescription medicinal products could be delivered directly to patients as per §59(10) AMG (Austrian Medicines Act).
Q4 -
Q5 -
Q6 §57 AMG (Austrian Medicines Act), exception: Authorised or registered, non-prescription medicinal products could be delivered directly to patients as per §59(10) AMG (Austrian Medicines Act).
Q7 §57, §59(1), (9) AMG (Austrian Medicines Act)
Q8 -
Q9 (For non-prescription medicinal products only), packaging and labelling must not be changed, IMP must be from trial stock
Q10 -
Q11 -
Q12 The use of advanced and qualified electronic signatures is accepted. Integrity and authenticity of the signature must be undisputable.
Q13 -
Q14 -
Q15 Allowed for original electronic medical records only. The electronic medical record system must be validated for that purpose.
Recommendation paper DCT, V02, 1 October 2025 26
BG
Q1 It is possible, but it will be assessed on a case by case basis with respect to the character of the particular IMP and the medical condition.
Q2 It is possible, but the pharmacy must be part of the approved trial site. It will be assessed on a case by case basis with respect to the character of the particular IMP and the medical condition.
Q3 -
Q4 -
Q5 -
Q6 -
Q7 -
Q8 -
Q9 -
Q10 -
Q11 Face to face meeting between the trial participant and the PI or a member of the research team is always mandatory during the consent procedure.
Q12 It is possible to electronically sign the Informed consent form (ICF), as the only permissible method is using qualified electronic signature (оnly qualified electronic signature issued by a licensed provider), replacing the handwritten signature but without fully digitalizing the entire informed consent process.
Q13
It is possible, but it will be assessed on a case by case basis. In case that clinical trial activities will be carried out outside the trial site, the location outside the site shall be indicated with the name of the medical institution, the structure therein and the exact address of the activity, as well as the names and qualifications of the relevant person carrying out the activity, where applicable. The information should be present in the Site Suitability Form and in the ICF. Home visits are generally not allowed, except in limited cases after assessment.
Q14 -
Q15 in certain cases- Information should be provided and assessed.
CY
Q1 Any exemption is subject to a justified request and a case-by-case assessment and approval.
Q2 Any exemption is subject to a justified request and a case-by-case assessment and approval.
Q3 -
Q4 -
Q5 -
Q6 -
Q7 IMP delivery to investigational sites is possible upon a case-by-case assessment and approval.
Q8 Not addressed in the national pharmaceutical legislation. Case by case assessment and approval.
Q9 -
Q10 -
Q11 -
Q12 -
Q13 Case-by-case assessment. Comprehensive documentation and adherence to GCP guidelines is expected.
Q14 Case-by-case assessment. Comprehensive documentation and adherence to GCP guidelines is expected.
Q15 Case by case assessment. Comprehensive documentation and adherence to GDPR rules and GCP guidelines is expected.
Recommendation paper DCT, V02, 1 October 2025 27
CZ
Q1
It is possible, but it will be assessed on a case by case basis with respect to the character of the particular IMP and its pharmaceutical form (tablets, infusion etc.) It would not be possible in case of IMPs that need to be diluted or reconstituted before administration, because these operations have to be carried out by healthcare professionals appointed by the healthcare service provider (Section 79 (10) of Act no. 378/2007 Coll., on Medicinal Products). The sponsor must then proceed in accordance with national guideline VYR-44, available on SUKL’s website.
Q2
It is possible if the pharmacy is closely connected with the trial site. It is possible then to deliver IMPs directly to trial participants from the pharmacy based on investigator´s request. But it will be assessed on a case by case basis with respect to the character of the particular IMP and its pharmaceutical form (tablets, infusion etc.) It would not be possible in case of IMPs that need to be diluted or reconstituted before administration, because these operations have to be carried out by healthcare professionals appointed by the healthcare service provider (Section 79 (10) of Act no. 378/2007 Coll., on Medicinal Products). The sponsor must then proceed in accordance with national guideline VYR-44, available on SUKLS’s website.
Q3
It is possible if the pharmacy is connected with the trial site per contract. It is possible then to deliver IMPs directly to trial participants from the pharmacy based on investigator´s request. But it will be assessed on a case by case basis with respect to the character of the particular IMP and its pharmaceutical form (tablets, infusion etc.) It would not be possible in case of IMPs that need to be diluted or reconstituted before administration, because these operations have to be carried out by healthcare professionals appointed by the healthcare service provider (Section 79 (10) of Act no. 378/2007 Coll., on Medicinal Products). The sponsor must then proceed in accordance with national guideline VYR-44, available on SUKLS’s website.
Q4 In general, the trial site pharmacy or PI is responsible for IMP handling. (Section 75 (5) and section 77 Act no. 378/2007 Coll., on Medicinal Products). Also, in line with the GCP the sponsor must not know trial participant's identification.
Q5 In general, the trial site pharmacy or PI is responsible for IMP handling. (Section 75 (5) and section 77 Act no. 378/2007 Coll., on Medicinal Products) Also, in line with the GCP the sponsor must not know trial participant's identification.
Q6 In general, the trial site pharmacy or PI is responsible for IMP handling. (Section 75 (5) and section 77 Act no. 378/2007 Coll., on Medicinal Products)
Q7 -
Q8 Delegated pharmacy can label IMP, but it must be treated contractually in case that delegated pharmacy and trial site are not the same legal entities.
Q9 In general, the trial site pharmacy or PI is responsible for IMP handling. (Section 75 (5) and section 77 Act no. 378/2007 Coll., on Medicinal Products)
Q10 In general, the trial site pharmacy or PI is responsible for IMP handling. (Section 75 (5) and section 77 Act no. 378/2007 Coll., on Medicinal Products)
Q11 But in accordance with Act no. 378/2007 Coll., on Medicinal Products, an investigator must always be a physician and only the investigator is responsible for dialogue with the participant during the consent procedure.
Q12
In our view, it is possible to use a qualified electronic signature in accordance with Regulation (EU) no. 910/2014 of the European Parliament and of the Council of 23 July 2014 on Electronic Identification and Trust Services for Electronic Transactions in the Internal Market and Repealing Directive 1999/93/EC (the „eIDAS regulation“). However, given that the acceptability of electronic signatures concerns all EU member states and the approach should be harmonised, we recommend to confirm with the European Commission should there be any differing views.
Q13 Home care is possible in the CZ, but with certain limits – please see more information on the website here https://sukl.gov.cz/en/en-reg-kh-doplnujici-informace/home-care-3/
Q14 Due to safety of patients. Supervision of a physician is necessary due to situations where potential action from a physician would be required in case of any urgent emergency (risk procedure etc.) In such case remote supervision can put the participant in danger (connection loss, misunderstanding in communications etc.)
Q15 It is only possible in trial sites, where all documentation is in electronical form in validated IT systems. But as the medical records are currently available in the paper form at the trial sites, the remote access is not allowed. With the ongoing digitization of healthcare systems at the trial sites, the remote access to the medical data will be reviewed case by case.
Recommendation paper DCT, V02, 1 October 2025 28
DE
Q1 Not subject to CT legislation
Q2 Certain restrictions for e.g. hospital pharmacies may apply.
Q3 -
Q4
In principle: Not allowed. According to Section 47 (1) sentence 1 number 2 letter g German Medicinal Product Act pharmaceutical entrepreneurs and wholesalers may only supply pharmacy only medicinal products only then directly and only to hospitals and doctors if the medicinal products are labelled "Intended for clinical trials", provided they are supplied free of charge. Exceptions: According to an exemption valid until 31. December 2023, the NCA may, by way of derogation from Section 47 (1) sentence 1 number 2 letter g AMG, permit pharmaceutical entrepreneurs (also: sponsors) and wholesalers to make medicinal products labelled for clinical trials available free of charge to participants in a clinical trial if, after an assessment to be carried out by the sponsor on a case-by-case basis, the safety of the persons participating in the clinical trial and the validity of the data collected in the clinical trial are guaranteed and the pseudonymisation of the data is ensured by appropriate measures that the trial participants have the right to contact the sponsor. This should be reflected in the protocol
Q5
Q6 See explanation to Q4; only for pharmacy licence holders
Q7 Section 47 (1) sentence 1 number 2 letter g and section 73 (2) number 2 German Medicinal Product Act.
Q8 It is crucial, that the manufacturer or the pharmacy has a manufacturing license
Q9
Q10
Q11
Face to face meeting not subject to German Medicinal Product Act. According to Model Professional Code for Physicians of the German Medical Association exclusive counselling or treatment via communication media is permitted in individual cases if this is justifiable from a medical point of view and the required medical care is observed, in particular by the way in which the findings are ascertained, counselling, treatment and documentation are carried out and the patient is also informed about the special features of exclusive counselling and treatment via communication media.
Q12 Only possible, when qualified electronical signature (eIDAS)
Q13 Possible in principle, but medical activities must be carried out by a physician
Q14
„In principle, yes, subject to the qualification requirements under national law for the medical personnel to whom a task is assigned; a number of medical tasks may according to national law only be performed by physicians (with a medical license to „In principle, yes, subject to the qualification requirements under national law for the medical personnel to whom a task is assigned; a number of medical tasks may according to national law only be performed by physicians (with a medical license to practice medicine
Q15 In principle, yes, provided that the investigators can and does comply with their obligation to maintain the confidentiality of his patients' health records; therefore, the responsibility for answering this question is with the respective investigator
DK
Q1 -
Q2 -
Q3 Yes, for hospital pharmacies.
Q4 A framework is being developed and will be provided in national guidance.
Q5 A framework is being developed and will be provided in national guidance.
Q6 -
Q7 -
Q8 -
Q9 If dispensed and then delivered according to normal prescription practice and taken by pharmacy standard stock of medicinal products.
Q10 -
Q11 The physical face-to-face meeting is the primary expectation, but video-based communication can be accepted in certain situations, as per decision of the ethical committee.
Q12 Currently both NemID (OCES standard) and MitID (eIDAS-compliant) is accepted.
Q13 -
Q14 -
Q15 Please consult the DKMA DCT guidance for specific requirements if utilised for rSDV.
Recommendation paper DCT, V02, 1 October 2025 29
EE
Q1 -
Q2 Not allowed for hospital pharmacies
Q3 The conditions and procedure for the issue of prescriptions for medicinal products and for the dispensation of medicinal products by pharmacies and the format of the prescription
Q4 Medicinal Products Act
Q5 Medicinal Products Act
Q6 Medicinal Products Act
Q7 -
Q8 Re-labelling is restricted to associated pharmacy
Q9 The conditions and procedure for the issue of prescriptions for medicinal products and for the dispensation of medicinal products by pharmacies and the format of the prescription
Q10 The conditions and procedure for the issue of prescriptions for medicinal products and for the dispensation of medicinal products by pharmacies and the format of the prescription
Q11 If justified. Remote authentication and facial recognition.
Q12 Qualified electronic signature (Smart ID, Mobile ID and ID card)
Q13 -
Q14 Case by case
Q15 Remote SDV not allowed
EL
Q1 Direct shipment to the patient is not addressed in CT legislation. In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q2 Direct shipment to the patient is not addressed in CT legislation. In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q3 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q4 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q5 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q6 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q7 Yes, however IMPs are shipped to the trial site (not to specific investigators).
Q8 -
Q9 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q10 In general, the trial site Head of hospital pharmacy or PI is responsible for IMP handling. Ministerial Decree O.J. 4131/2016, Art 6.
Q11 Although not specifically addressed in CT legislation, a face-to-face meeting is implied. Ministerial Decree O.J. 4131/2016, Art. 9. In addition, the National Ethics Committee interpretation is that a face-to-face meeting is required for the provision of Informed Consent.
Q12 In general, electronic signatures are acceptable in Greece. However, CT specific legislation does not address the issue. The National Ethics Committee requires wet ink signatures.
Q13 Ministerial Decree O.J. 4131/2016, Art. 3
Q14 Not specifically addressed in current CT legislation
Q15 -
Recommendation paper DCT, V02, 1 October 2025 30
ES
Q1 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ) (however this activity should be managed by the Pharmacy Department [unless the site has no Pharmacy]).
Q2 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ)
Q3 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ). It is covered by Autonomous Communities legislation (e.g. Law 19/1998 the organization of pharmaceutical services in Madrid)
Q4 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ)
Q5 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ)
Q6 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ). It is covered by Autonomous Communities legislation (e.g. Law 19/1998 the organization of pharmaceutical services in Madrid)
Q7 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ). Except if the trial site has no Pharmacy Department.
Q8 Regulation 536/2014 article 61.5 a). If the delegated pharmacy is taking part in the same clinical trial in the same Member State.
Q9 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ)
Q10 Real Legislative Decree 1/2015 article 3.6 c) and Royal Decree 1090/2015 article 39.3 ñ)
Q11 Physical face to face is not specifically established by any national provisions.
Q12 If high level of eIDAS and if the confidentiality of the personal data, data security and secure access to the data is ensured. See national Guidelines for undertaking decentralised items in clinical trials
Q13 If an adequate investigator oversight and proper contractual arrangements between sponsor, trial site and investigator is ensured. Data protection aspects should also be considered.
Q14 Certain tasks/procedures should be defined in order to provide proper assessment. General Data Protection Regulation (GDPR) should be addressed in this regard.
Q15 There are no specific national provisions; GDPR covers this aspect in the entire EU and should be considered.
FI
Q1 -
Q2 In special and justified circumstances only
Q3 Medicinal Act §15 b. Fimea Administrative Regulation 2/2016
Q4 Medicinal Act §15 b. Medicinal Act §31
Q5 Medicinal Act §15 b
Q6 Medicinal Act §17. Medicinal Act §15a
Q7 Medicinal Act §17
Q8 Medicinal Act §15a
Q9 Fimea Administrative Regulation 2/2016
Q10 Fimea Administrative Regulation 2/2016
Q11 -
Q12 The national Client Data Act 703/2023 8 and 22§: the participant should be identified reliably (authentication. for example suomi.fi or respective) and the signature method must be advanced or qualified.
Q13 -
Q14 -
Q15 -
Recommendation paper DCT, V02, 1 October 2025 31
FR
Q1 The shipment to patient home by PUI (hospital pharmacy) are allowed by 'retrocession' (article L. 5126-6 CSP). For experimental drugs in the context of a CT and in absence of any legal specification, ANSM and Ethics Committees may accept it.
Q2 The shipment to patient home by PUI is allowed by 'retrocession' (article L. 5126-6 CSP). For experimental drugs in the context of a CT and in absence of any legal specification, ANSM and Ethics Committees may accept it.
Q3 -
Q4 In accordance with art R 5124-2 and -3 of CSP
Q5 -
Q6 As per French legislation.
Q7
Yes, but under conditions for the shipping to the investigators as per article L 5126-7 of CSP. PUIs are allowed to provide investigators of the same CT or professionals with similar activities outside of France (article R 5124-4 of CSP), with experimental drugs. In the same way dispensers of experimental drugs who are based outside of France, may be allowed to provide French investigators of the same CT with experimental drugs. However, these deliveries should be in conformity with articles L5121-108 and L5124-13 of CSP and customs code (importation authorization if clinical trial is not already authorized). Under these conditions the ANSM may agree. The labelling should be in French language.
Q8 The community pharmacy is not allowed to label experimental drugs. The labelling of experimental drugs should be performed either by a pharmaceutical entity with a GMP manufacturing authorization, or by a PUI pharmacy with authorization of preparing products needed for clinical trials (article R.5126-9 CSP).
Q9 Not possible for a PUI pharmacy in a hospital that is not involved in the given clinical trial (article L. 5126-1 CSP). Possible for a community pharmacy under conditions of article D. 5125-45-1 of CSP - if specified in the protocol, the ANSM may agree.
Q10 Not possible (article L. 5126-1 and D. 5125-45-1 of CSP)
Q11 Not mandatory
Q12
Based on the following legal references: - Article L1122-1-1 alinéa 1st of CSP & article 1367 of Civil code. - The European regulation (UE) number 910/2014 of European Parlement and of Counsil of 23 juillet 2014 concerning the electronic identification does distinguish three types of electronic signatures: the simple electronic signature, the advanced signature (article 26 of regulation) and qualified signature. The e-consent is legal (via these 3 categories of signature) but not yet used in France under this scope.
Q13 Provided that the delegation is appropriately planned in the study protocol and validated by competent authorities. This possibility allows to involve the private physicians who work outside the hospitals in clinical studies.
Q14 As of today, it is not forbidden in the regulation. As a consequence, it is allowed for a given trial provided that there is no opposition from ANSM or from the Ethics Committees.
Q15 Fulfilling the recommendations of the CNIL (French DPA) about regulation and sensitive data protection. cf. provisional recommendations during the Covid crisis (https://www.cnil.fr/fr/recommandations-provisoires-controle-qualite- essais-cliniques-crise-sanitaire)”
Recommendation paper DCT, V02, 1 October 2025 32
HR
Q1 The IMP must be managed by trial site pharmacy or PI.
Q2 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q3 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q4 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q5 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q6 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q7 IMP can be delivered to principal investigator from wholesale licence holders located in other EU MSs.
Q8 According to the Medicinal Product Act only wholesale distributors with a manufacturing authorisation are allowed to perform labelling of IMPs.
Q9 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q10 According to the Medicinal Product Act only wholesale distributors can distribute medicinal products and the IMP is dispensed to the participant by the trial site pharmacy or PI.
Q11 Physical face to face meeting between the trial participant and the PI or a member of the research team is yet mandatory in Croatia.
Q12 Although not specifically addressed in CT legislation, the use of qualified electronic signatures is accepted.
Q13 -
Q14 It depends on the task/procedure.
Q15
If on-site SDV is not possible, remote SDV is allowed if EU (EC, EMA, HMA) GUIDANCE ON THE MANAGEMENT OF CLINICAL TRIALS DURING THE COVID-19 (CORONAVIRUS) PANDEMIC is respected. Remote SDV must be submitted as substantial protocol amendment to CEC/RA and must be precisely specified in the protocol as to how it will be carried out. Permission to perform remote monitoring should be previously carefully considered with clinical trial site and prior permission and agreement must be reached between the site and the sponsor/CRO.
HU
Q1 -
Q2 -
Q3 -
Q4 -
Q5 -
Q6 -
Q7 -
Q8 -
Q9 -
Q10 -
Q11 35/2005. (VIII. 26.) Health Ministry Decree
Q12 e-IDAS Art. 6., 7. , 26. , 27. , 36. , 37.
Q13 Consent of the trial participant to the home visits does not reduce in any aspect the responsibilities of the PI.
Q14 Consent of the trial participant to the home visits does not reduce in any aspect the responsibilities of the PI.
Q15 In case of emergency remote SDV should be allowed if EMA „GUIDANCE ON THE MANAGEMENT OF CLINICAL TRIALS DURING THE COVID-19 (CORONAVIRUS) PANDEMIC (most recent version)” is respected with special attention to paragraph 11. d) and Annex 1. In general, the prerequisite of RSDV may not be less stringent.
Recommendation paper DCT, V02, 1 October 2025 33
IE
Q1 Could be allowed on case-by-case basis, when justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA.
Q2 Could be allowed on case by case basis, when justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA
Q3 Could be allowed on case by case basis, when justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA
Q4 An MIA in itself does not provide for direct distribution to clinical trial participants
Q5 Could be allowed on case by case basis, when justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA
Q6 Could be allowed on case by case basis, when justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA. The IMP should comply in all respects with details which have been approved as part of the clinical trial application in Ireland e.g. labelling.
Q7 The IMP should comply in all respects with details which have been approved as part of the clinical trial application in Ireland e.g. labelling.
Q8 In accordance with the terms of CTR Art 61.5, S.I. No. 99/2022 and the HPRA Guide to Registration of Processes Exempted under Article 61(5) of the CTR. Generally recommended to speak with the HPRA.
Q9 When justified and clearly described in the clinical trial application. Generally recommended to speak with the HPRA
Q10 -
Q11 -
Q12 -
Q13 -
Q14 Dependant on task
Q15 There are no provisions in national legislation which prohibit remote access to medical records. However, such access can only be permitted by the institution / persons responsible for control of the data, in consideration of application data protection requirements.
No footnotes for: IS
IT
Q1 -
Q2 -
Q3 National guideline published on Aug 2024 allowing direct delivery
Q4 National guideline published on Aug 2024 allowing direct delivery
Q5 National guideline published on Aug 2024 allowing direct delivery
Q6 National guideline published on Aug 2024 allowing direct delivery
Q7 Not according to the current provisions for CT according to Directive; national provisions for CT according to CTR are to be made available shortly
Q8 -
Q9 National guideline published on Aug 2024 allowing direct delivery
Q10 National guideline published on Aug 2024 allowing direct delivery
Q11 (CTR art.29 does not foresee a face to face interview, no additional national provision exists on this aspect)
Q12 PADES electronic signature on pdf files is surely accepted; other formats (e.g. CADES) to be confirmed
Q13 -
Q14 -
Q15 In compliance with the GDPR
No footnotes for: LI
Recommendation paper DCT, V02, 1 October 2025 34
LT
Q1 National legislation does not foresee the delivery of IMP directly to trial participants. Nevertheless, the IMP delivery from trial site to trial participant could be allowed on case by case basis, when justified and clearly described in the clinical trial application.
Q2 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q3 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q4 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q5 -
Q6 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q7 -
Q8 Re-packing and re-labelling can be performed in the hospital pharmacy, associated with the clinical trial site: The Order of the Minister of Health of the Republic of Lithuania No V-571 regarding the procedure of re-packing and re-labelling of IMPs at the clinical trial sites
Q9 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q10 Law of pharmacy https://www.e-tar.lt/portal/lt/legalActEditions/TAR.FF33B3BF23DD
Q11 -
Q12 Qualified electronic signature should be used.
Q13 Delegation of specific functions is possible, contract needed with the relevant and licensed Health care institutions.
Q14 -
Q15 Yes, if electronic medical records are used and access to medical records of particular patient is feasible.
LU
Q1 It is delivered by the hospital pharmacist to the investigator who then delivers it to the patient.
Q2 The delivery is coordinated by the hospital pharmacy. The pharmacist provides the investigator with the IMP.
Q3 Clinical trials are only performed in hospitals in Luxembourg, and there are no delegated pharmacies for IMPs. IMPs can only be managed by hospital pharmacies.
Q4 -
Q5 -
Q6 -
Q7 -
Q8 -
Q9 -
Q10 -
Q11 -
Q12 Not applicable as not yet done in practice.
Q13 Delegated tasks are performed by qualified research team members.
Q14 It depends on the clinical trial and task/procedure modalities
Q15 -
LV
Q1 No restrictions in national legislation
Q2 No restrictions in national legislation
Q3 No restrictions in national legislation
Q4 Delivery to patients is acceptable if patient’s confidentiality is ensured.
Q5 Licensed depot is deemed acceptable for IMP delivery directly to the trial participants. Not specifically mentioned in national legislation.
Q6 -
Q7 -
Q8 -
Q9 -
Q10 -
Q11 The physical face-to-face meeting is the primary expectation, but video-based communication can be accepted in certain situations, as per decision of the ethical committee.
Q12 -
Recommendation paper DCT, V02, 1 October 2025 35
Q13 -
Q14 Case-by-case evaluation
Q15 As the medical records are currently mainly available in the paper form at the trial sites, the remote access is possible only if justified. For electronic records access is possible if justified. On site SDV is preferred option.
MT
Q1 Activity has to be approved so a request should be made to the Medicines Authority
Q2 Activity has to be approved so a request should be made to the Medicines Authority
Q3 -
Q4 -
Q5 -
Q6 -
Q7 -
Q8 -
Q9 -
Q10 -
Q11 -
Q12 -
Q13 -
Q14 -
Q15 -
NL
Q1 Only in specific circumstances, see Medicines Act (Geneesmiddelenwet), 61.2.
Q2 Medicines Act (Geneesmiddelenwet), article 61.2.
Q3 Medicines Act (Geneesmiddelenwet), article 61.2.
Q4 Medicines Act (Geneesmiddelenwet), article 34.2 and 61.2.
Q5 -
Q6 Medicines Act (Geneesmiddelenwet), article 61.2, 61.5 and 61.6.
Q7 Medicines Act (Geneesmiddelenwet), article 34.2 and 61.2.
Q8 Medicines Act (Geneesmiddelenwet) article 18.1 and 18.7.
Q9 Under the conditions mentioned in Medicines Act (Geneesmiddelenwet) articles 18.1, 34.2 and 61.2.
Q10 -
Q11 However, see requirements in article 6 of the Medical Research Involving Human Subjects Act (Wet medisch-wetenschappelijk onderzoek met mensen), especially 6.5, 6.6 and 6.7.
Q12 Article 6.2 of the Medical Research Involving Human Subjects Act (Wet medisch-wetenschappelijk onderzoek met mensen). Guidance on electronic signature (in Dutch): https://www.ccmo.nl/onderzoekers/publicaties/publicaties/2022/08/31/handreiking-elektronische-toestemmingsverlening
Q13 Taking into account the requirements mentioned in the Healthcare Professionals Act (Wet op de beroepen in de individuele gezondheidszorg).
Q14 Taking into account the requirements mentioned in the Healthcare Professionals Act (Wet op de beroepen in de individuele gezondheidszorg).
Q15 Taking into account the requirements mentioned in the General Data Protection Regulation (GDPR).
NO
Q1 NoMA defines "deliver" as physical delivery to patient, and not shipment. Shipment to patient must be applied for and approved by NoMA.
Q2 -
Q3 -
Q4 Forskrift om tilvirkning og import av legemidler § 3-2/Forskrift om grossistvirksomhet § 13
Q5 Forskrift om tillvirkning og import av legemidler § 3-2 /Forskrift om grossistvirksomhet § 13
Q6 Forskrift om tillvirkning og import av legemidler § 3-2/forskrift om grossistvirksomhet § 13
Recommendation paper DCT, V02, 1 October 2025 36
Q7 Forskrift om tillvirkning og import av legemidler § 3-2/forskrift om grossistvirksomhet § 13
Q8 Pharmacies with a “pharmacy manufacturing license” are allowed to re-label IMP. Only pharmacies with an ordinary MIA can label IMP.
Q9 Provided agreement with the sponsor (Apotekforskriften § 27 g)
Q10 Provided agreement with the sponsor (Apotekforskriften § 27 g)
Q11 -
Q12 Qualified electronic like for instance BankID is acceptable.
Q13 Provided contractual arrangement
Q14 -
Q15 No national legislations regulating such activities. However, compliance with GDPR is a prerequisite as well as adherence to local procedures.
PL
Q1 Poland indicated acceptance of this solution in 2022 but it is not specifically addressed in current PL legislation
Q2 -
Q3
Public pharmacies do not IMPs. 68.1 pharmaceutical law (u.p.f). Retail trade in medicinal products is carried out in generally accessible pharmacies, subject to the provisions of para. 2, art. 70 sec. 1 I art. 71 sec. 1. When Art. 86 par. 2a upf pharmaceutical services referred to in art. 4 sec. 3 points 5 and 7 of the Act of 10 December 2020 on the pharmaceutical profession and professional tasks referred to in art. 4 sec. 4 points 1, 2, 5-7, 15 and 16 of this Act, may be provided only in a hospital pharmacy, company pharmacy or hospital pharmacy separated from these pharmacies" (Article 4 paragraph 4 point 2 of the Act - "Examination in auxiliary tests including research conducted in the hospital as a member of the research team.” Thus, community pharmacies cannot provide IMP for research.
Q4
No. Annex 13 of the Regulation GMP defines the obligations of the manufacturer of investigational medicinal products, including the points below are as follows: point 44. The distribution of investigational medicinal products is carried out in accordance with the instructions given by or on behalf of the sponsor in the distribution order. 46. Detailed inventory records of shipments of investigational product sent by the manufacturer or supplier shall be maintained. In particular, it includes data identifying recipients. Currently, the PF Act, art. 42 par. 2 point 2 defines to which entities the manufacturer/importer may distribute medicinal products, there is no direct recipient - study participant listed there.
Q5 -
Q6 No, in relation to generally available pharmacies - they cannot participate in clinical trials, they can only trade medicinal products - Art. 68 sec. 1 u.p.f.
Q7 No, in relation to generally available pharmacies - they cannot participate in clinical trials, they can only trade medicinal products - Art. 68 sec. 1 u.p.f.
Q8 Not. Any delegated pharmacy may not label the IMP, this is limited to the pharmacy associated with the study site. Article 38b upf
Q9
Pharmaceutical services referred to in Art. 4 sec. 3 points 5 and 7 of the Act of 10 December 2020 on the profession of a pharmacist, and the professional tasks referred to in art. 4 sec. 4 points 1, 2, 5-7, 15 and 16 of this Act, may be provided only in a hospital pharmacy, company pharmacy or a hospital pharmacy department established instead of these pharmacies" (Article 4 paragraph 4 point 2 of the u.o.z.f - "participation in research clinical trials, including trials conducted in a hospital as a member of the research team". Thus, generally accessible pharmacies cannot provide IMPs to trial participants. This is the task of a hospital pharmacy, an in-house pharmacy, a medical entity where a clinical trial is conducted
Q10 as above
Q11
In accordance with the Act on the professions of physician and dentist Art. 42. 1. A physician shall rule on the health status of a given person after previously examining him personally or examining him via teleinformatic systems or communication systems (...)
Q12 Currently qualified electronic signature is required.
Q13 Poland indicated acceptance of this solution in 2022 but it is not specifically addressed in current PL legislation
Q14 Poland indicated acceptance of this solution in 2022 but it is not specifically addressed in current PL legislation
Q15 Not forbidden
Recommendation paper DCT, V02, 1 October 2025 37
PT
Q1 As long as shipping conditions are kept under control.
Q2 As long as shipping conditions are kept under control.
Q3 To be assessed on a case-by-case basis; IMP circuit should be clearly and in detail described in the CT protocol.
Q4 To be assessed on a case-by-case basis; IMP circuit should be clearly and in detail described in the CT protocol.
Q5 Article 32nd, Law 21/2014, from the 16th of April, current version.
Q6 Article 32nd, Law 21/2014, from the 16th of April, current version.
Q7 To be assessed on a case-by-case basis; IMP circuit should be clearly and in detail described in the CT protocol.
- Pharmacies with a “pharmacy manufacturing license” are allowed to re-label IMP. Only pharmacies with an ordinary MIA can label IMP.
Q9 Article 32nd, Law 21/2014, from the 16th of April, current version; the pharmacies must be included on the IMP circuit described in detail in the CT protocol
Q10 Article 32nd, Law 21/2014, from the 16th of April, current version
Q11 Dialogue is mandatory
Q12 On a case-by-case basis; wet ink use should also be possible, along with e-signatures; according to the EC website, reuse of CEF eID sample implementation software is described as being implemented in Portugal; please refer to Autenticacao.gov.pt
Q13 Healthcare provider must be in direct dependency of the IP
Q14 Should be clearly specified in the CT protocol
Q15 This should be approached under the EU GDPR. Remote monitoring may be performed using video or by sending the de-identified data via email using secure means. Direct remote access to the site´s patient records computer systems is not allowed
RO
Q1 -
Q2 In Romania, authorizes activities for pharmacies are explicitly mentioned in the Pharmacy Law nr 266/2008 which permit shipping activities only for OTC medicines
Q3 In Romania, authorizes activities for pharmacies are explicitly mentioned in the Pharmacy Law nr 266/2008 which permit shipping activities only for OTC medicines
Q4 -
Q5 Based on authorisation issued by ANMDMR
Q6 -
Q7 -
Q8 -
Q9 In Romania, authorizes activities for pharmacies are explicitly mentioned in the Pharmacy Law nr 266/2008 which permit shipping activities only for OTC medicines
Recommendation paper DCT, V02, 1 October 2025 38
Q10 In Romania, authorizes activities for pharmacies are explicitly mentioned in the Pharmacy Law nr 266/2008 which permit shipping activities only for OTC medicines
Q11 -
Q12 Advanced electronic signature/ Qualified electronic signatures
Q13 Only if it is an accredited medical service provider
Q14 Not yet. National provisions are under development
Q15 -
SE
Q1 If relevant national legislation (for example "Lag (2009:366) om handel med läkemedel") is followed.
Q2 If relevant national legislation (for example "Lag (2009:366) om handel med läkemedel") is followed. Any pharmacy that is handling IMPs for a clinical trial site should have a CT specific delegation (either from site or sponsor/CRO) and established routines for handling IMP.
Q3 If relevant national legislation (for example "Lag (2009:366) om handel med läkemedel") is followed. Any pharmacy that is handling IMPs for a clinical trial site should have a CT specific delegation (either from site or sponsor/CRO) and established routines for handling IMP.
Q4 -
Q5 -
Q6 Current interpretation of "Lag (2009:366) om handel med läkemedel"
Q7 Current interpretation of "Lag (2009:366) om handel med läkemedel"
Q8
Labelling of IMPs in pharmacies is restricted to e.g. auxiliary labelling of authorised IMPs, if performed in accordance with relevant national pharmacy legislation. Please refer also to national legislation HSLF-FS 2021:109. Any pharmacy that is handling IMPs for a clinical trial site should have a CT specific delegation (either from site or sponsor/CRO) and established routines for handling IMP.
Q9 If relevant national legislation (for example "Lag (2009:366) om handel med läkemedel") is followed. Any pharmacy that is handling IMPs for a clinical trial site should have a CT specific delegation (either from site or sponsor/CRO) and established routines for handling IMP.
Q10 If relevant national legislation (for example "Lag (2009:366) om handel med läkemedel") is followed. Any pharmacy that is handling IMPs for a clinical trial site should have a CT specific delegation (either from site or sponsor/CRO) and established routines for handling IMP.
Q11 -
Q12 The system used (level of category) is the responsibility of the sponsor.
Q13 If relevant national healthcare legislation and hospital practices allows for it.
Q14 If relevant national healthcare legislation and hospital practices allows for it.
Q15 -
Recommendation paper DCT, V02, 1 October 2025 39
SI
Q1 In case the trial site is a Hospital, the IMP must be managed by Hospital pharmacy Art 62, Par 3 and Par 7 of Pharmacy Practice Act
Q2 Always under supervision of the investigator of the trial site
Q3 In case the trial site is a Hospital, the IMP must be managed by Hospital pharmacy article 67 point 7 (1)
Q4 In case the trial site is a Hospital, the IMP must be managed by Hospital pharmacy article 67 point 7 (1)
Q5 Only in exceptional situation (IMP shortage due to for example COVID-19 lock-down and should be on the basis of a risk assessment with patient safety as utmost priority and only after agreement with the investigator and on the basis of the investigator’s prescription.
Q6 In case the trial site is a Hospital, the IMP must be managed by Hospital pharmacy article 67 point 7 (1) Only after agreement with the investigator and on the basis of the investigator’s prescription.
Q7 In case the trial site is a Hospital, the IMP must be managed by Hospital pharmacy article 67 point 7 (1) Only after agreement with the investigator and on the basis of the investigator’s prescription.
Q8 Delegated pharmacy must comply with special requirements in accordance with Article 13 Par 2.
Q9 It is not appropriate if IMP is blinded. Under oversight of investigator of trial site. The trial drug must be marketed and used within the approved indication (according to the SmPC).
Q10 It is not appropriate if IMP is blinded. Under oversight of investigator of trial site. The trial drug must be marketed and used within the approved indication (according to the SmPC).
Q11 In accordance to ICH GCP The investigator, or a person designated by the investigator, should fully inform the participant or the participant’s legally acceptable representative, of all pertinent aspects of the trial & and should answer all participant questions. The communication of this information should be documented.
Q12 Currently, there is no established practice.
Q13 -
Q14 depending on the procedure/task
Q15
If on-site SDV is not possible for a longer period of time due to for example lock-down due to pandemic, remote rSDV must be submitted as substantial protocol amendment to EC/RA and must be precisely specified in the protocol as to how it will be carried out, so that the rights of the participants will be protected and will not unnecessarily burden the staff at the trial site who must agree to such a method of data verification. Monitors should sign a written confidentiality agreement committing to securely destroy any copy of redacted documents, whether paper or electronic, as soon as they have been used for source data verification and committing not to make any copy (or recording in the case of video access) of any non-pseudonymised document.
References from SI: (1) Pharmacy Practice Act (Official Gazette of the RS, no. 85/16, 77/17, 73/19 and 186/21)
(2) Regulation on the implementation of the Regulation (EU) on clinical trials of medicinal products for human use (Official Gazette of the Republic of Slovenia, No. 132/22)
SK
Q1
Q2
Q3
Q4
Q5
Q6
Q7
Q8
Q9 Pharmacist must be delegated by PI.
Q10 Pharmacist must be delegated by PI.
Q11
Q12 Qualified electronic signature for investigator and participant is required according to the Act No. 272/2016 on credible services for electronic transaction for domestic trade. According to the EU regulation, the new forms of eIDAS are AsiC-E, AsiC-S and are acceptable.
Q13
Q14 According to § 2(46) of Act No. 576/2004 Coll. on Health Care, Services Related to the Provision of Health Care, and on the Amendment and Supplementation of Certain Acts
Q15
