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