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Navigating Regulatory Landscapes - FDA, EMA, & MHRA

Posting date: 05/05/2025
Author: Inside ICON

Navigating Regulatory Landscapes:     Comparing FDA, EMA, & MHRA in Clinical Trials

In clinical research, no matter how promising a new therapy may be, it will go nowhere without regulatory approval. Understanding the regulatory frameworks of the world’s major oversight agencies is critical not only for sponsors and CROs but also for the professionals building careers in this space.

The U.S. Food and Drug Administration (FDA), the European Medicines Agency (EMA), and the UK’s Medicines and Healthcare products Regulatory Agency (MHRA) are three of the most influential regulatory authorities in global drug development. While they share a mission to ensure the safety, efficacy, and quality of medicinal products, their approaches differ across jurisdictional boundaries.

In this blog, we compare these three agencies across five key areas: jurisdiction, application processes, timelines, pharmacovigilance, and harmonisation. We also explore how professionals can align their careers with these regulatory requirements.

Jurisdiction and Scope of Authority

FDA – United States  The FDA is the central authority responsible for regulating pharmaceuticals, biologics, medical devices, and dietary supplements in the U.S. It has binding legal authority to approve or reject marketing applications. The FDA also enforces compliance through inspections, warning letters, and import restrictions.

EMA – European Union The EMA operates as a central scientific assessment body for all EU member states. It does not itself issue marketing approvals; that responsibility rests with the European Commission. However, the EMA's assessments are typically accepted without objection. It serves a coordinating function among national competent authorities (NCAs).

MHRA – United Kingdom Following Brexit, the MHRA became an independent regulatory agency. It governs clinical trial approvals, marketing authorizations, and post-marketing surveillance within the UK. It has adopted a more agile model, including rolling reviews and international reliance frameworks.

Timelines and Expedited Review Programs

FDA The FDA offers multiple expedited programs for therapies addressing unmet medical needs:

  • Fast Track

  • Breakthrough Therapy Designation

  • Accelerated Approval

  • Priority Review

These designations shorten timelines and encourage early dialogue with the agency.

EMA The EMA offers Priority Medicines (PRIME) and Accelerated Assessment pathways for high-impact therapies. Under Accelerated Assessment, reviews can be completed within 150 days (vs. the standard 210). 

MHRA The MHRA has introduced Rolling Reviews, allowing sponsors to submit data packages incrementally. It also participates in global regulatory collaborations, such as Access Consortium and Project Orbis, which offer accelerated assessments based on shared review outputs.

Post Marketing Surveillance and Pharmacovigilance

FDA The FDA mandates ongoing safety reporting through the FDA Adverse Event Reporting System (FAERS). For high-risk drugs, it may require Risk Evaluation and Mitigation Strategies (REMS) to manage known or potential risks. Compliance is enforced through inspections and post-market commitments. 

EMA The EMA coordinates EU-wide pharmacovigilance through the EudraVigilance database. Companies must submit Periodic Safety Update Reports (PSURs) and maintain Risk Management Plans (RMPs). Signal detection and risk minimization strategies are centrally reviewed by the Pharmacovigilance Risk Assessment Committee (PRAC). 

MHRA The MHRA continues to use the Yellow Card Scheme for collecting adverse event data. The agency has also created the Innovative Licensing and Access Pathway (ILAP), which includes early engagement and risk-proportionate oversight mechanisms post-launch.

International Harmonisation and Collaboration

Despite operational differences, the FDA, EMA, and MHRA all participate in global initiatives to streamline regulatory science: 

  • International Council for Harmonisation (ICH): Aligns technical requirements for pharmaceuticals.
  • Project Orbis: Facilitates simultaneous review of oncology drugs by the FDA, MHRA, and others.
  • Access Consortium: Includes regulatory authorities from the UK, Canada, Singapore, Australia, and Switzerland to expedite approvals. 
  • WHO Prequalification: Supports international access to medicines through alignment on quality standards. 

These collaborations help sponsors avoid redundant reviews and enable faster access to new therapies across markets.

Career Advice

For professionals in clinical research, whether you're a CRA, regulatory affairs associate, clinical trial manager, or medical writer, understanding the regulatory environments in key markets is a valuable differentiator. 

Here’s a few reasons why: 

  • Global trials are the norm. Knowledge of how to prepare documentation that satisfies FDA, EMA, and MHRA simultaneously is critical for global protocols. 
  • Compliance drives employability. Being conversant with GCP guidelines, IND/CTA processes, and pharmacovigilance requirements increases your credibility in interviews and in practice. 
  • Regulatory roles are growing. Roles in regulatory operations, submissions management, and strategic affairs are expanding as the regulatory landscape grows more complex. 
  • Certifications matter. Earning credentials like the RAC (Regulatory Affairs Certification) or completing courses on ICH-GCP, EU CTR, or FDA IND processes can fast-track your entry into regulatory or quality-focused roles. 

Whether you’re entry-level or mid-career, staying current on changes such as the EU CTR implementation or MHRA’s evolving post-Brexit role makes you a more strategic asset to employers.

Conclusion

The FDA, EMA, and MHRA all have the same mission: protect public health and ensure the benefits of new medical products outweigh their risks. But the way they execute that mission varies. For clinical research professionals and organisations, those differences carry operational, strategic, and career implications.

Understanding how each regulator operates helps build smarter trials, better applications, and stronger professional credibility. As global regulatory landscapes evolve, staying informed is essential.

If you're interested in a Regulatory career in the Clinical Research industry, view our current Regulatory Affairs openings at ICON today.
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