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.
- 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.
- 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Europe already publishes a detailed report explaining why each drug was approved. If every country did, smaller regulators could reuse the work.
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.
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.
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.
Trials are inspected to check the data are real and traceable. Do the same for the hospital databases used to make regulatory decisions.
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.
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.
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.
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.
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.
Drugs approved on early evidence come with follow-up obligations. One of them should be finding out how tumours escape the new drug.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Companies currently reformat the same evidence for every country; a single machine-readable dossier that every regulator reads from would save years of work.
Preparing a regulatory filing requires expensive specialist software and consultants. Free, open tools would let universities and small generic firms file in more countries.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Pages like this
not linked directly; found by shared links- BottleneckIncentives reward me-too drugs and marginal gains
Shares Sponsors deposit the confirmatory trial budget in escrow at accelerated approval, Conditional approvals that lapse automatically if the confirmatory trial is late, Serplulimab, Breakthrough Therapy / Priority Review / Priority Voucher.
- BottleneckPrices and value
Shares One evidence plan agreed by regulator and payer before the pivotal trial, Provisional prices for surrogate-endpoint approvals, reset when survival data arrive, Approve cancer biosimilars on analytics and pharmacokinetics, no efficacy trials, WHO prequalification plus pooled demand to push biosimilar prices below 10% of the originator.
- BottleneckMost of the world has almost no cancer care
Shares 90-day reliance approval for cancer drugs cleared by two stringent regulators, Fund an oncology joint assessment unit inside the African Medicines Agency, Live tracker of the lag from first approval to real availability in every country, Comisión Federal para la Protección contra Riesgos Sanitarios.
- TermTumour-agnostic (tissue-agnostic) approval
Shares A fast route to the matched drug when it is licensed for another cancer, Adopt tumour-agnostic cancer drug labels across regions by reliance, not re-review, Reciprocal recognition of tumour-agnostic and rare-indication approvals across regulators, A standard for tumour-agnostic approvals: minimum histologies and hierarchical modelling.
- BottleneckTrials do not represent the people who get cancer
Shares One multiregional trial, no bridging studies: enforce ICH E17 in Japan and China, A global open trials operating system any hospital can plug into, Jiangsu Hengrui Pharmaceuticals, Akeso.
- BottleneckAI that is built but not validated or deployed
Shares A regulatory sandbox for continuously learning cancer AI, A shared AI review assistant that maps one dossier to every regulator's questions, External validation at five or more sites in two countries before clearance, Continuous prospective validation for every oncology AI tool after deployment.
- BottleneckWeak real-world evidence and registries
Shares Good practice standards and inspection for real-world data sources, One international registry, not one per country, for conditional approvals, Require post-approval evidence in patients over 75 and update labels accordingly, Every patient on an accelerated-approval drug enrolled in a registry until confirmation.
- BottleneckRare and paediatric cancers without markets
Shares Automatic reciprocity of orphan and rare-paediatric designations between regulators, One global paediatric cancer development plan instead of separate FDA and EMA plans, A standing rulebook for one-patient treatments, Adopt tumour-agnostic cancer drug labels across regions by reliance, not re-review.