OnCo
bottlenecksBottleneck

Regulatory divergence between regions

Regulatory divergence means a drug approved in one country can take years to reach another, or never arrive.

Every major regulator (FDA, EMA, MHRA, PMDA, NMPA, TGA, Health Canada) requires its own dossier, applies its own evidence standards, and reviews on its own timeline, and approval is followed by a separate reimbursement process in each country. The result is a staggered global launch in which the same drug can be available in the US a year before the EU and years before Japan or China, or never filed at all in small or low-income markets. Sponsors also run duplicate or bridging trials to satisfy region-specific requirements, and divergent decisions on accelerated approvals create confusion about what the evidence actually shows. Harmonisation through ICH, collaborative review (Project Orbis, the Access Consortium), reliance pathways for smaller regulators, and the EU's joint clinical assessment are narrowing the gap, but the sequence of separate national decisions remains the norm.

majorregulation manufacturing59 ideas to fix it
How big the problem is
303 vs 366 vs 352 days
Median total review time for novel therapeutics at FDA vs EMA vs Health Canada, 2001-2010
7 partner regulators alongside FDA (Australia, Brazil, Canada, Israel, Singapore, Switzerland, UK)
Countries participating in FDA Project Orbis concurrent review of oncology products
Root causes
  • National sovereignty over drug approval means each agency must reach its own decision on its own dossier.
  • Evidence standards differ, especially on surrogate endpoints, single-arm trials and accelerated approval.
  • Reimbursement and health technology assessment are separate from approval and differ in every country.
  • Small and low-income markets are filed last or not at all because expected revenue does not cover the cost of filing.
  • Requirements for local trial data (historically in Japan and China) forced duplicate bridging studies.
What is already being tried
  • FDA Project Orbis coordinates concurrent review of oncology applications with partner regulators, cutting the lag to approval in participating countries.
  • The Access Consortium (Australia, Canada, Singapore, Switzerland, UK) shares work on dossiers, and the MHRA International Recognition Procedure relies on trusted regulators' decisions.
  • ICH guidelines (including E17 on multi-regional trials) harmonise technical requirements, and China's NMPA accepts overseas data since 2017 reforms.
  • The EU Health Technology Assessment Regulation began joint clinical assessments for oncology medicines in January 2025.
  • The WHO Collaborative Registration Procedure and prequalification let low-income regulators rely on stringent-authority approvals.
  • The EMA and FDA run parallel scientific advice so sponsors can design one trial that satisfies both.
What breaking it looks like
A single pivotal package supports simultaneous approval in all major regions within a few months of each other, and the median lag between first global approval and availability in any country with a functioning health system falls below one year.

Ideas to fix it

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early clinicalregulatorsmall cost
90-day reliance approval for cancer drugs cleared by two stringent regulators

If the FDA and EMA have both approved a cancer drug, a smaller country should be able to approve it in three months using their reports rather than starting over.

speculativeregulatormedium cost
A fast route to the matched drug when it is licensed for another cancer

Sometimes a progression biopsy shows exactly which drug would help, but it is licensed for another cancer and cannot be obtained. A standing pathway would fix that.

speculativeregulatormedium cost
A global first-in-human network for academic cancer trials with single ethics review

Academic first-in-human trials recruit slowly because each hospital repeats ethics and regulatory review. A network of phase 1 units with one shared review would open trials in many countries at once.

speculativeengineeringlarge cost
A global open trials operating system any hospital can plug into

Build the shared software, legal templates and data standards that let any hospital in the world join a cancer trial in weeks instead of years, the way the internet let any computer join the network.

early clinicalregulatorsmall cost
A mandatory patient-experience section in every cancer drug label and approval

The official information about a new cancer drug must include what patients on the trial actually reported about side-effects and daily life, not only survival curves.

speculativephilanthropymedium cost
A non-profit company to hold marketing authorisations for repurposed cancer drugs

Someone must legally own a drug's licence to update its label and monitor safety. A non-profit could do this for old drugs proven to work in cancer that no company wants.

speculativedatasmall cost
A public index of how the same cancer drug's label differs between countries

Nobody keeps track of how differently the same drug is approved and dosed around the world. A public scoreboard would make the differences visible and push regulators to converge.

speculativeregulatorsmall cost
A regulatory pathway for new radiotherapy techniques modelled on drug development

New ways of giving radiotherapy are adopted without the staged testing that drugs go through, and are then hard to evaluate. A defined pathway with fee waivers and clear evidence steps would bring rigour without blocking progress.

early clinicalregulatormedium cost
A regulatory sandbox for continuously learning cancer AI

Let AI tools that improve as they learn be used under close supervision in a few hospitals, with pre-agreed rules for what changes are allowed and how they are checked.

speculativeregulatorsmall cost
A reliance pathway for companion diagnostics so the test arrives with the drug

Targeted cancer drugs often reach a country years before the test needed to select patients is approved there. Recognising other regulators' test approvals would close the gap.

early clinicalregulatormedium cost
A shared AI review assistant that maps one dossier to every regulator's questions

Regulators are starting to use AI to read dossiers faster. If they shared one tool, it could show where their questions overlap and where they truly disagree.

speculativeregulatorsmall cost
A standard for tumour-agnostic approvals: minimum histologies and hierarchical modelling

Some drugs are approved for any cancer with a particular mutation. Clear rules on how many cancer types must be tested, and how to combine results across them, would make these approvals more consistent and faster.

speculativeregulatorsmall cost
A standing rulebook for one-patient treatments

Sometimes a treatment must be designed for a single patient. Agreeing in advance what evidence and safety checks are needed would make that fast, fair and learnable.

speculativeregulatorsmall cost
Adopt tumour-agnostic cancer drug labels across regions by reliance, not re-review

Some drugs work on a genetic change whatever the cancer. When one regulator approves such a label, others should adopt it rather than demanding trials per cancer type.

speculativeregulatorsmall cost
Agree in advance how to borrow evidence between similar rare cancers

Statistical methods can combine information across similar rare cancers to reach an answer with fewer patients. Regulators need to say in advance when that is acceptable.

being tested at scaleregulatorsmall cost
Approve cancer biosimilars on analytics and pharmacokinetics, no efficacy trials

Copies of biological cancer drugs are still required to run large trials that rarely change the answer. Dropping them would cut years and tens of millions from each biosimilar.

speculativeregulatorsmall cost
Automatic reciprocity of orphan and rare-paediatric designations between regulators

A rare cancer drug designated 'orphan' in the US must reapply in Europe, Japan and elsewhere. Recognising each other's decisions would save small companies months.

speculativeregulatormedium cost
Comparability by design: a digital twin and sentinel panel for cell process changes

Improving how a cell therapy is made currently risks having to repeat clinical trials. A validated computer model plus a fixed set of product measurements would let changes be approved on data alone.

early clinicalregulatorsmall cost
Conditional approvals that lapse automatically if the confirmatory trial is late

Drugs approved early on promising results should lose that approval automatically if the company fails to finish the follow-up trial by the agreed date.

early clinicalregulatormedium cost
Continuous prospective validation for every oncology AI tool after deployment

Cancer AI tools are approved on old test data and then never checked again. Require every deployed tool to report its real-world performance continuously, in public.

speculativeregulatormedium cost
Develop drugs in children first when the target is a children's target

Children wait years for drugs because adult trials come first, even when the target belongs to a childhood cancer. Some drugs should start with children.

speculativeregulatormedium cost
Every patient on an accelerated-approval drug enrolled in a registry until confirmation

Drugs approved early on promising but unproven results would have every treated patient followed in a registry, so we know within two years whether the promise held.

early clinicalregulatorsmall cost
Every regulator publishes its full assessment report so others can rely on it

Europe already publishes a detailed report explaining why each drug was approved. If every country did, smaller regulators could reuse the work.

speculativeregulatorsmall cost
External validation at five or more sites in two countries before clearance

No cancer AI would be approved until it has been tested on patients from at least five different hospitals in at least two countries, none of which contributed training data.

speculativephilanthropymedium cost
Fund an oncology joint assessment unit inside the African Medicines Agency

Africa's new continental medicines agency could assess cancer drugs once for 55 countries. It needs oncology reviewers and a reliance rule to do it.

early clinicalregulatorsmall cost
Get the one approved appetite drug licensed beyond a single country

A drug that improves appetite and lean weight in cancer wasting is approved in Japan but almost nowhere else. Reviewing the existing evidence could widen access quickly.

early clinicalregulatormedium cost
Good practice standards and inspection for real-world data sources

Trials are inspected to check the data are real and traceable. Do the same for the hospital databases used to make regulatory decisions.

early clinicalpolicysmall cost
Harmonise Europe's hospital exemption for academic cell therapies, with one registry

Spain lets hospitals make and use their own CAR-T under a special rule; most European countries do not. A common rule with shared outcome tracking would spread affordable academic products.

early clinicalregulatormedium cost
Hospital-exemption cell therapies at scale, backed by a shared registry

European law already lets hospitals make advanced therapies for their own patients. Pair that with a shared outcomes registry so academic CAR-Ts and similar treatments can prove themselves without a commercial licence.

early clinicalregulatorsmall cost
Joint FDA-EMA-MHRA-PMDA scientific advice by default before pivotal cancer trials

Before a company runs its big trial, all the major regulators should agree together on the design in one meeting, so the same trial can be approved everywhere.

early clinicalregulatorsmall cost
Let non-profits and academics add a cancer indication to an off-patent drug's label

Only the manufacturer can ask regulators to add a new use to a drug's label, and generic makers have no reason to. Universities and charities should be allowed to apply.

speculativedatasmall cost
Live tracker of the lag from first approval to real availability in every country

A drug approved in the US may take five years to reach a patient in Poland or never reach Nigeria. A live public tracker would show exactly where and why it is stuck.

speculativeregulatorsmall cost
Make post-progression sampling a condition of accelerated approval

Drugs approved on early evidence come with follow-up obligations. One of them should be finding out how tumours escape the new drug.

early clinicalregulatorsmall cost
Make pre-approval dose optimisation an ICH standard so it is done once worldwide

The FDA now asks companies to find the right dose of a cancer drug before approval. If every regulator asked the same way, companies would do it once and doses would match worldwide.

early clinicalregulatorsmall cost
Manufacturing-change passport: one approved CMC change accepted everywhere in 30 days

Changing how a cancer drug is made must be approved separately in over a hundred countries, which takes years and causes shortages. One approval should count for all.

speculativeregulatorsmall cost
Mutual recognition of ethics review across countries

A trial approved by a qualified ethics committee in one country would not need to repeat the full review in another; the second country would accept the first review and check only local issues.

early clinicalregulatorsmall cost
Mutual recognition of GMP inspections for cell, gene and radiopharmaceutical plants

Factories making living or radioactive cancer medicines are inspected separately by each country. Accepting each other's inspections would free up inspectors and speed supply.

speculativeregulatormedium cost
One clinical trial application accepted by regulators in every major region

Starting a cancer trial in ten countries means ten applications and ten ethics reviews. One shared application and a common ethics template would start trials months sooner.

early clinicalregulatorsmall cost
One ethics approval and one consent form for a platform trial across countries

Adding a new arm to an international platform trial currently needs approval in every country again. A single, pre-agreed process would let arms open in weeks.

early clinicalpayersmall cost
One evidence plan agreed by regulator and payer before the pivotal trial

Regulators want proof a drug works; payers want proof it is worth the price. Agreeing both requirements at once would stop drugs being approved but then not paid for.

early clinicalregulatorsmall cost
One global paediatric cancer development plan instead of separate FDA and EMA plans

Companies must agree separate plans for testing new cancer drugs in children with US and European regulators. A single agreed plan would get children access sooner.

early clinicalresearchmedium cost
One global rare cancer network with n-of-1 and Bayesian trial frameworks

Rare cancers are collectively common but each is too rare for normal trials. Link every rare cancer patient worldwide into one network with registries and trial designs built for small numbers.

speculativeregulatormedium cost
One international registry, not one per country, for conditional approvals

When a drug is approved early, each country often demands its own follow-up study. A single shared registry would answer the safety questions faster and better.

early clinicalregulatorsmall cost
One multiregional trial, no bridging studies: enforce ICH E17 in Japan and China

Japan and China have often required extra local studies before accepting a global trial. Committing to accept well-designed global trials would bring drugs to Asian patients years earlier.

early clinicalpolicysmall cost
One national master contract and budget template for all cancer trials

Contract negotiation between a hospital and a drug company often takes longer than the trial's first patient. A single pre-agreed contract and budget template, used by everyone, would cut months off opening a trial.

speculativeregulatormedium cost
One structured global dossier: submit the cancer drug file once, to a shared cloud

Companies currently reformat the same evidence for every country; a single machine-readable dossier that every regulator reads from would save years of work.

speculativeengineeringsmall cost
Open-source dossier-building software for academic sponsors and generic makers

Preparing a regulatory filing requires expensive specialist software and consultants. Free, open tools would let universities and small generic firms file in more countries.

early clinicalregulatorsmall cost
Platform designation for ADC linker-payloads so manufacturing data carry across

Many antibody-drug conjugates share the same linker and payload chemistry. Regulators should let companies reuse the manufacturing evidence rather than repeating it for every new antibody.

speculativeregulatorsmall cost
Pre-agreed update rules so an MCED test is not obsolete when its trial reads out

A cancer blood test improves every year, but a ten-year trial tests the old version. Regulators and sponsors could agree in advance how updates are validated and carried into the result.

early clinicalpayersmall cost
Provisional prices for surrogate-endpoint approvals, reset when survival data arrive

Drugs approved on early signs of benefit are paid for as if they had proved they extend life. Pay a provisional price and adjust it, up or down, when the survival data come in.

early clinicalregulatorsmall cost
Publish every complete response letter and negative opinion across all regulators

When a regulator rejects a cancer drug, the reasons are usually secret. Publishing them everywhere would stop other countries and companies repeating the same mistakes.

early clinicalregulatorsmall cost
Reciprocal recognition of tumour-agnostic and rare-indication approvals across regulators

When a trusted regulator approves a cancer drug for a rare genetic target, other countries should recognise that approval within months instead of repeating years of review.

early clinicalregulatormedium cost
Regional cyclotron hubs for actinium-225 with an agreed actinium-227 impurity limit

Actinium-225 can be made in particle accelerators, but the product contains a trace of a long-lived impurity that regulators have not agreed how to handle. Settle the limit and build the hubs.

speculativeregulatorsmall cost
Regulators recognise each other's companion diagnostic approvals

A test approved to select patients for a drug in the US must go through separate approval in Europe, Japan and elsewhere, delaying the drug. Accepting each other's test approvals would fix the delay.

speculativeregulatormedium cost
Require post-approval evidence in patients over 75 and update labels accordingly

New cancer drugs are approved on trials of younger, fitter patients, then given mostly to older ones. Regulators should require real-world safety and benefit data in the over-75s and put it on the label.

speculativepolicysmall cost
Sponsors deposit the confirmatory trial budget in escrow at accelerated approval

To get an early approval, a company would set aside the money for the follow-up trial up front, so the trial cannot be quietly abandoned.

early clinicalregulatormedium cost
Stream trial data to regulators as it accrues; review starts at last patient visit

Instead of waiting months for a company to package trial results, regulators would see the data flow in during the trial and could decide within weeks of it ending.

being tested at scaleregulatorsmall cost
Turn Project Orbis into a work-sharing review with one shared assessment report

Regulators in several countries already look at the same cancer drug dossier at the same time. Let them split the work and write one report instead of six.

early clinicalregulatormedium cost
WHO prequalification plus pooled demand to push biosimilar prices below 10% of the originator

Cheap copies of key antibody drugs exist but many countries cannot check their quality. A WHO quality stamp plus large pooled orders would make them safe to buy and very cheap.

What relieves it today

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Key papers

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rctThe Lancet 2025
HARMONi-2: ivonescimab, a PD-1 x VEGF bispecific, beats pembrolizumab head-to-head in PD-L1-positive lung cancer

For the first time a new drug has beaten pembrolizumab, the global first-line standard, in a randomised lung cancer trial, and it did so by combining checkpoint blockade with anti-angiogenesis in one molecule. For patients outside China nothing changes yet: the drug is not approved in the West, the trial was single-country, and survival benefit has not been shown. If confirmed in the global HARMONi-3 and HARMONi-7 trials, PD-1 x VEGF bispecifics could replace PD-1 antibodies as the immunotherapy backbone.

rctThe Lancet 2021changed practice
CheckMate 649: nivolumab plus chemotherapy as first treatment for advanced gastric, gastro-oesophageal junction and oesophageal adenocarcinoma

Patients with newly diagnosed advanced stomach or oesophageal adenocarcinoma whose tumour is HER2-negative and PD-L1 positive (CPS 5 or more, or at least 1 in some regions) should receive chemotherapy with nivolumab (or pembrolizumab, from KEYNOTE-859), which adds about three months of median survival and doubles the chance of being alive at three years. The benefit in PD-L1-negative tumours is doubtful, and these patients may be better served by chemotherapy alone or by trials.

reviewNew England Journal of Medicine 2021changed practice
FDA's Project Optimus manifesto: cancer drugs are approved at doses that are too high

The dose on the label is often not the best dose for patients; it is the highest one that was tolerable for a few weeks. Project Optimus means new cancer drugs should arrive with evidence on dose, and it gives clinicians licence to consider dose reduction for toxicity. For older drugs, the evidence gap persists.

translationalScience 2017changed practice
Le 2017: mismatch-repair deficiency predicts response to PD-1 blockade across twelve tumour types, leading to the first tissue-agnostic drug approval

This paper established a new regulatory paradigm: a drug approved for a molecular feature regardless of organ. It made MSI/MMR testing standard across advanced cancers and remains the clearest example of a biomarker that works across histologies. It also anchored the idea that mutation load, via neoantigens, is what makes tumours visible to T cells.

meta analysisJAMA Internal Medicine 2015
Prasad: most surrogate endpoints in cancer trials correlate poorly with survival

A drug that shrinks tumours or delays progression on scans has not necessarily been shown to help patients live longer or better. Patients and clinicians should ask what the endpoint was; regulators should insist on timely confirmatory trials; and trialists should validate surrogates before relying on them.

Connected

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ideas

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90-day reliance approval for cancer drugs cleared by two stringent regulatorsA fast route to the matched drug when it is licensed for another cancerA global first-in-human network for academic cancer trials with single ethics reviewA global open trials operating system any hospital can plug intoA mandatory patient-experience section in every cancer drug label and approvalA non-profit company to hold marketing authorisations for repurposed cancer drugsA public index of how the same cancer drug's label differs between countriesA regulatory pathway for new radiotherapy techniques modelled on drug developmentA regulatory sandbox for continuously learning cancer AIA reliance pathway for companion diagnostics so the test arrives with the drugA shared AI review assistant that maps one dossier to every regulator's questionsA standard for tumour-agnostic approvals: minimum histologies and hierarchical modellingA standing rulebook for one-patient treatmentsAdopt tumour-agnostic cancer drug labels across regions by reliance, not re-reviewAgree in advance how to borrow evidence between similar rare cancersApprove cancer biosimilars on analytics and pharmacokinetics, no efficacy trialsAutomatic reciprocity of orphan and rare-paediatric designations between regulatorsComparability by design: a digital twin and sentinel panel for cell process changesConditional approvals that lapse automatically if the confirmatory trial is lateContinuous prospective validation for every oncology AI tool after deploymentDevelop drugs in children first when the target is a children's targetEvery patient on an accelerated-approval drug enrolled in a registry until confirmationEvery regulator publishes its full assessment report so others can rely on itExternal validation at five or more sites in two countries before clearanceFund an oncology joint assessment unit inside the African Medicines AgencyGet the one approved appetite drug licensed beyond a single countryGood practice standards and inspection for real-world data sourcesHarmonise Europe's hospital exemption for academic cell therapies, with one registryHospital-exemption cell therapies at scale, backed by a shared registryJoint FDA-EMA-MHRA-PMDA scientific advice by default before pivotal cancer trialsLet non-profits and academics add a cancer indication to an off-patent drug's labelLive tracker of the lag from first approval to real availability in every countryMake post-progression sampling a condition of accelerated approvalMake pre-approval dose optimisation an ICH standard so it is done once worldwideManufacturing-change passport: one approved CMC change accepted everywhere in 30 daysMutual recognition of ethics review across countriesMutual recognition of GMP inspections for cell, gene and radiopharmaceutical plantsOne clinical trial application accepted by regulators in every major regionOne ethics approval and one consent form for a platform trial across countriesOne evidence plan agreed by regulator and payer before the pivotal trialOne global paediatric cancer development plan instead of separate FDA and EMA plansOne global rare cancer network with n-of-1 and Bayesian trial frameworksOne international registry, not one per country, for conditional approvalsOne multiregional trial, no bridging studies: enforce ICH E17 in Japan and ChinaOne national master contract and budget template for all cancer trialsOne structured global dossier: submit the cancer drug file once, to a shared cloudOpen-source dossier-building software for academic sponsors and generic makersPlatform designation for ADC linker-payloads so manufacturing data carry acrossPre-agreed update rules so an MCED test is not obsolete when its trial reads outProvisional prices for surrogate-endpoint approvals, reset when survival data arrivePublish every complete response letter and negative opinion across all regulatorsReciprocal recognition of tumour-agnostic and rare-indication approvals across regulatorsRegional cyclotron hubs for actinium-225 with an agreed actinium-227 impurity limitRegulators recognise each other's companion diagnostic approvalsRequire post-approval evidence in patients over 75 and update labels accordinglySponsors deposit the confirmatory trial budget in escrow at accelerated approvalStream trial data to regulators as it accrues; review starts at last patient visitTurn Project Orbis into a work-sharing review with one shared assessment reportWHO prequalification plus pooled demand to push biosimilar prices below 10% of the originator

collections

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key papers

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