OnCo
ideasIdea

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.

FDA began publishing complete response letters in 2025; EMA publishes refusal assessment reports; most other regulators publish nothing on negative decisions. Sponsors routinely describe rejections selectively. The proposal is a standing commitment across ICH members to publish all negative decisions and their reasons within 30 days, indexed alongside approvals, so that other regulators can rely on negative as well as positive assessments and developers can learn what evidence was insufficient.

Hypothesis
Systematic publication of rejections reduces resubmissions with the same deficiency and reduces the number of products approved in one region after rejection in another for the same evidence package.
Rationale
Negative decisions carry as much information as positive ones and currently reach only the sponsor. Publication also deters approval shopping between jurisdictions.
What would test it
Analyse the first two years of published FDA CRLs for oncology to quantify the share disclosed accurately by sponsors beforehand; extend publication commitments through ICH and monitor resubmission patterns.
Maturity
early clinical
Who has to act
regulator
Cost to try
Small (under $1M)
Years to first evidence
2
Bottlenecks it attacks
  • Regulatory divergence between regions · Regulatory divergence means a drug approved in one country can take years to reach another, or never arrive.
  • Failures are hidden · Negative trials, failed drugs and abandoned programmes are rarely published, so the same mistakes are repeated.

Connected

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