Legal Framework
The new EU Regulation No 536/2014 (Clinical Trials Regulation, CTR) came into force on 31 January 2022. It concerns the new way in which clinical drug research is conducted in the European Union (EU). The Regulation harmonises the procedures for the submission, assessment and monitoring of clinical drug trials in the EU through the Clinical Trials Information System (CTIS).
The legal framework at national level for the processing of applications for clinical trials submitted in accordance with Regulation (EU) No 536/2014 is described in the legal texts below.
• Law of 7 May 2017 on clinical trials of medicines for human use (FR-version)
• Royal Decree of 9 October 2017 implementing the Law of 7 May 2017 on clinical trials of medicines for human use (FR-version)
To determine whether a clinical study falls under the European Regulation as a clinical trial, the decision tree (Annex I in Q&A document) can be consulted.
Contents of a CTR dossier for a clinical trial
European requirements
The contents of a CTR dossier for a clinical trial are described in Annex I to the Clinical Trials Regulation.
The templates of the application documents in Part II were developed by the European Commission and can be found in Chapter I of EudraLex, Volume 10.
• Recruitment and Informed consent procedure template
• Compensation for trial participants
• Template for declaration of interest by the principal investigator
Information specific to Belgium
In Belgium, there are some specific requirements regarding the content of the CTR dossier for clinical trials. These are described in the link of requested documents for Belgium, which is updated twice a year.
Central information system (CTIS)
CTIS is the central access point for submitting applications for clinical trials within the EU and the European Economic Area (EEA) and it consists of several components.
• A workspace for clinical trial sponsors and the organisations that work in collaboration with them. The secure sponsor workspace assists clinical trial sponsors in preparing their application and compiling the supporting documentation to be submitted for assessment.
• A workspace for the competent authorities of the EU Member States and EEA countries, and for the European Commission. This secure workspace for authorities supports the activities of EU Member States, EEA countries, and the European Commission in the assessment and supervision of clinical drug trials.
• The public will have access to detailed information on all clinical trials conducted in the EU and EEA through the public website once applications are submitted and approved through CTIS.
The EU Member States and EEA countries will assess and monitor clinical trials in CTIS. The European Medicines Agency (EMA) builds and maintains CTIS. The European Commission will ensure the correct interpretation and implementation of the Clinical Trials Regulation.
Processing of clinical drug trials in CTIS
Clinical trial sponsors seeking approval for a clinical trial in one or more EU/EEA Member States will be required to submit only one application form and the supporting dossier through CTIS. The submission of the clinical trial application form and supporting dossier also includes the public registration of the clinical trial.
CTIS will support the day-to-day business processes of EU Member States, EEA countries and sponsors throughout the duration of a clinical trial. The system will provide regulatory oversight of clinical trials and tools for supervision and monitoring.
Registration for the use of CTIS
Parties wishing to use CTIS must have an EMA account. Users who already have an EMA account, for example to use EudraVigilance or the Substance, Product, Organisation and Referentials Database (SPOR), do not need to create a new account. Users who do not have an EMA account can register through the EMA account management facility.
Organisations may need to go through additional registration steps based on the user management approach that was used for CTIS. The organisation-centred approach enables user management by an administrator at organisation level, rather than at the level of an individual trial. This is intended for organisations that run various trials through CTIS. To make use of this organisation-based approach, organisations must ensure that they are registered in the EMA organisation management system and must register a CTIS High Level Administrator through the EMA account management facility.
More information about CTIS
• General information about the Clinical Trials Regulation and CTIS
• CTIS handbook and frequently asked questions (FAQ) for clinical trial sponsors
• EMA also offers training sessions for additional learning opportunities. Video recordings of these 'walk in clinics' or 'bitesize talks' and supporting materials are available on this page
• Clinical Trial Highlights Newsletter
• Clinical Trials Regulation – EudraLex, Volume 10, Clinical trials guidelines
• A Q&A document from the European Commission provides answers to frequently asked questions about the CTR.
Retributions
Retributions and taxes for clinical trial applications are payable in accordance with the 2022 FAMHP financing law (information available in Dutch or French).
- For non-commercial clinical trials, a fee exemption (zero fee) applies in Belgium.
- For commercial trials, detailed information on the applicable fees can be found on the page ‘Research and development’ (available in Dutch or French).
Invoicing
The retributions are payable only after an invoice has been issued by the FAMHP. Invoices are addressed exclusively to the sponsor. Each invoice will include the relevant information on the clinical trial, such as:
- the clinical trial number;
- the application ID;
- the sponsor and the designated legal representative;
- the application type;
- the submission date;
- the applicable fees.
Fee exemption for resubmissions due to CTIS technical issues
As of 1 January 2026, no invoice for CTR safety assessment and ethics committee assessment will be issued for resubmissions caused by CTIS‑related technical issues that occurred after validation, on the condition that the content of the submission package is identical to the validated submission package of the original submission.
After submitting your resubmission, you must request the fee exemption by sending an email to ct.rd@fagg-afmps.be with the subject line ‘xxxx-xxxxxx-xx-xx_resubmission_invoice_exemption’.
The e-mail should include:
- the application ID;
- a confirmation statement that the resubmission package is identical to the original one after validation (please mention the EU CT number, application ID and submission date of the original one), with no substantial, non‑substantial, or typographical changes. Only elements that must be updated for the new submission, such as study numbers, version numbers, and dates, should be adapted.
- evidence that the resubmission is due to CTIS technical issues, such as documentation that the original application was lapsed or withdrawn at the request of the EMA, accompanied by the corresponding EMA ticket mentioning the EU CT number, application ID and submission date and confirming the technical problem.
Resubmissions will be processed in the same way as the initial submission, meaning that the RFI will be re‑issued and responses will need to be resubmitted. This will of course depend on the exact moment of the bug throughout the application procedure.
This measure is not applicable for:
- bugs occurring before validation, as the original submission will not be charged;
- the GCP fee: as this fee is only being invoiced for authorised initial applications in Belgium, it will never be invoiced for a lapsed or withdrawn application. Consequently, this fee will still be invoiced for the resubmission if it concerns an authorised initial application in Belgium.
Contact
Division Research and Development