Compare Chapter 4 revision and Annex 22 · AI

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Chapter 4 revisionAnnex 22 · AI
AuthorityEuropean CommissionEuropean Commission
Legal weightGMP guide & annexesGMP guide & annexes
StatusDraftDraft
Last verifiedNot yetNot yet
Summary

Revised GMP documentation chapter, consulted on jointly with PIC/S. It updates expectations for records in any format, data governance and the documentation lifecycle, aligning with the revised Annex 11. Draft only.

The first EU GMP text written specifically for AI, drafted with PIC/S. It covers AI models used in GMP-critical applications and complements the revised Annex 11 and Chapter 4.

  • Static, deterministic models may be used in critical applications, subject to validation.
  • Dynamic models, generative AI and LLMs are kept out of critical uses in the current draft; non-critical use needs documented human oversight.
  • Whether generative AI can be allowed with guardrails was discussed at the June 2026 workshop.
Lifecycle
  • 7 Jul 2025 Draft published for public consultation
  • 7 Oct 2025 Public consultation closed
  • Target 31 Dec 2026 Target: final text to European Commission (Q4 2026)
  • 7 Jul 2025 Draft published for public consultation
  • 7 Oct 2025 Public consultation closed
  • 30 Jun 2026 EMA multistakeholder workshop on comments and generative AI (30 Jun–1 Jul)
  • Target 31 Dec 2026 Target: final text to European Commission (Q4 2026)
SourceOfficial text
Source: European Commission. Licensed under CC BY 4.0.
Official text
Source: European Commission. Licensed under CC BY 4.0.

These facts are placed side by side from each record. This page does not say which is stricter or whether requirements differ. Read the official texts.