Skip to main content Skip to search Skip to main navigation

EMA: Concept Paper on the Revision of Annex 15

EMA and PIC/S have published a concept paper outlining a targeted revision of Annex 15 (Qualification and Validation).

Background of the revision
The revision is largely driven by the nitrosamine (sartan) case. The “lessons learnt” report identified shortcomings in process and product knowledge, validation practices, change control and contamination control among active substance manufacturers.

A key recommendation was to make Annex 15 mandatory for active substance manufacturers.

In addition, Annex 15 will be aligned with ICH Q9 (R1) on Quality Risk Management.

Key elements of the proposed revision

Qualification and Validation

  • Extension of scope to chemical and biological active substance manufacturers (mandatory application)
  • For API manufacturers strengthening of:
    • Validation Master File
    • Qualification & Validation policy
    • Investigation of results not meeting predefined acceptance criteria
    • Oversight of third-party validation activities
    • Supplier qualification
    • Process validation activities to process recovery of materials and solvents

GDP Principles
The integration of Good Distribution Practices (GDP) for active substances is foreseen. Expanded requirements for transport verification are planned.

ICH Q9 (R1)

Annex 15 is intended to be specifically aligned with the updated version of ICH Q9 (R1):

  • Stronger emphasis on Quality Risk Management (QRM) in design and validation of monitoring systems
  • Integration of risk reviews to support qualification and validation
  • Application of QRM also in the context of traditional processes

The public consultation will end on 9 April 2026. The revised Annex 15 is expected to be published by December 2026


Source:

EMA: Concept paper on the revision of the guidelines on Good Manufacturing Practice for medicinal products - Annex 15 - Qualification and Validation

Meet the GMP Compliance Adviser

The GMP Compliance Adviser is the world's largest knowledge portal for quality management in the pharma business. 

The demo access is non-binding and ends automatically.

Test it now for free

You may also be interested in the following articles:

EMA: Revision of Annex 15 Delayed

EMA: Revision of Annex 15 Delayed

In February 2026, the EMA published a concept paper on the revision of Annex 15 "Qualification and Validation" of the EU GMP Guide (we reported previously). The Agency has now released a corrected version containing a significantly revised timetable.
Read more
EU: Updated Q&A on Safety Features for Human Medicinal Products

EU: Updated Q&A on Safety Features for Human Medicinal Products

The European Commission has published Version 22 of its Questions and Answers on Safety Features for Medicinal Products for Human Use.
Read more
EMA: Q&A Paper on Measures to Prevent Microbial Contamination of Non-Sterile Medicinal Products

EMA: Q&A Paper on Measures to Prevent Microbial Contamination of Non-Sterile Medicinal Products

The EMA has published a new Q&A paper on technical and organisational measures to prevent microbial contamination of non-sterile medicinal products.
Read more
When APS Fail and First Air is at Risk

When APS Fail and First Air is at Risk

At the PDA Good Aseptic Manufacturing Conference 2026, Alberto Gonzales (Takeda) discussed challenges and practical solutions related to aseptic process simulations (APS). Anna Campanella (Takeda) and Hussein Bachir (Franz Ziel) explored how first air protection in aseptic processing can be compromised by equipment design, glove interventions, and operator activities.
Read more
Why is import authorisation necessary for medicinal products entering the EU?

Why is import authorisation necessary for medicinal products entering the EU?

Here's the answer:
Read more
FDA: Updated Compliance Program for Preapproval Inspections

FDA: Updated Compliance Program for Preapproval Inspections

The FDA has revised its Compliance Program 7346.832, “Preapproval Inspections”. The updated program describes the planning, conduct and evaluation of preapproval inspections (PAIs) for New Drug Applications (NDAs) and Abbreviated New Drug Applications (ANDAs).
Read more
Previous
Next