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Case study – small virtual EU-naïve sponsor based in California

  • Writer: Breffni Martin
    Breffni Martin
  • Dec 9, 2025
  • 2 min read

10th December 2025


We were approached by a “virtual” pharma, who had just completed a small first-in-human study in the US for a rare disease.  The outcome was positive so the company was interested in doing a phase 2a open label study in the US and the EU, with the aim of extending to a phase2b/3 type design if successful.

This company had no prior experience of working in the European Union. They engaged a small US based CRO who were helpful in the phase 1 study, but who lacked EU experience, so delays had started to arise when they contact us for advice. The company also complained about poor responsiveness to basic questions from the CRO in question.

Regintel was able to quickly move through the basic issues that were holding them back, which were:


  • Registration as an SME

  • Registration of the substance

  • Registration of a Research Product Indicator

  • Orphan Drug Designation application

  • Scientific advice at zero cost thanks to incentives

  • Subsequently, once advice was received work continued with the

  • Insertion of XEVMPD EV code, acting as Responsible Person for Eudravigilance

  • Acted as Legal Representative under the Clinical Trial Regulation and support for the CTIS CTA submission process

  • Acted as Data Protection Representative advising on data protection issues in the EU including

    • Policies

    • SOPs

    • Technical and Organisational Measures for compliance

    • Data protection training

    • Data flow analysis / implementation of Standard Contractual Clauses for export of data

    • Contracts with sites and vendors

    • Review of ICFs and Protocol

    • Record of Processing Activities and Data protection Impact Assessment

    • Dealing with RPIs


Because a Data Protection Officer was not required in the jurisdictions where the study was undertaken, this service was not needed, but was eventually engaged at the start of their follow-up study, which included Germany. RegIntel was able to provide this service as well through our retained DPO.


Because Regintel has extensive experience of these processes and can act very quickly, the initial delays were caught up and the results of the Phase 2a study were delivered on time.

Stage EU

Date

Stage USA

Initial contact

Feb 2022

IND preparation

SME

March 2022


Substance

March 2022


RPI

March 2022


RPEV/XEVMPD insertion

May 2022


ODD

July 2022

IND submission

Completion of compliance documentation

September 2022

FDA approval

Scientific advice

September 2022


Finalisation of submission documentation

October 2022

FDA study start

CTIS submission

November 2022


Approval

January 2022

FDA study completion

Study completed

March 2024


Study report

June 2024

FDA report


Overall project was completed on time and RegIntel’s final fees over the 29 months was 12% less than the initial budget.

 
 
 

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Breffni Martin, Templetown, Carlingford, County Louth, Ireland, A91 T923

 

E bmartin@regintel.com                O +353 429376740                 +353 879145363

 

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