ICH Q9(R1) and its 7 linked instruments

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ICH Q9(R1)Annex 11 revisionICH Q10Annex 15FDA data integrity Q&AFDA quality systems guideMHRA GxP data integrityEMA AI reflection paper
AuthorityICHEuropean CommissionICHEuropean CommissionFDAFDAMHRAEMA
Legal weightGuidance & Q&AGMP guide & annexesGuidance & Q&AGMP guide & annexesGuidance & Q&AGuidance & Q&AGuidance & Q&AGuidance & Q&A
StatusFinalDraftFinalIn forceFinalFinalFinalFinal
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Summary

The international guideline on quality risk management. It is the basis for scaling validation effort to risk in Annex 11, Annex 22 and computer software assurance, and the 2023 revision addresses subjectivity, formality and risk-based decision-making.

A full rewrite of Annex 11, published for consultation with the revised Chapter 4 and the new Annex 22. It expands expectations on supplier oversight, data integrity, audit trails, identity and access, cloud and outsourced services. Not yet in force: the 2011 Annex 11 still applies.

ICH model for an effective quality management system for the pharmaceutical industry.

The EU GMP annex on qualification and validation.

FDA's question-and-answer guidance on data integrity in drug manufacturing: ALCOA, audit trail review, access controls, shared logins and when electronic data are CGMP records.

FDA guidance to help manufacturers use modern quality systems and risk management to meet the CGMP regulations in 21 CFR parts 210 and 211.

UK guidance and definitions for data integrity across GxP areas, including data governance, ALCOA+, audit trails and computerised system controls.

EMA's current thinking on AI and machine learning for human and veterinary medicines, covering principles that apply at any stage of a medicine's lifecycle, from drug discovery to after authorisation.

Lifecycle
  • 9 Nov 2005 Original Q9 reached Step 4
  • 18 Nov 2021 Q9(R1) released for public consultation at Step 2
  • 18 Jan 2023 Reached Step 4 (final)
  • 16 Nov 2022 Concept paper on revising Annex 11 (EMA/INS/GMP/778340/2022)
  • 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, slipped from Q1 2026)
  • 8 Apr 2009 Published by FDA as guidance
  • 1 Oct 2015 Came into operation
  • ~1 Dec 2018 Final guidance published (Dec 2018)
  • 2 Oct 2006 Final guidance issued
  • 23 Jan 2015 Earlier GMP data integrity definitions and guidance first published
  • 13 Mar 2015 Earlier GMP guidance updated with clarifications
  • 9 Mar 2018 Published
  • 4 Apr 2018 Earlier GMP guidance withdrawn, replaced by this GxP guidance
  • 19 Jul 2023 Draft released for public consultation
  • 31 Dec 2023 Public consultation closed
  • 9 Sep 2024 Final version adopted by CHMP
  • 30 Sep 2024 Final version published
SourceOfficial text
Source: ICH.
Official text
Source: European Commission. Licensed under CC BY 4.0.
Official text
Source: ICH.
Official text
Source: European Commission. Licensed under CC BY 4.0.
Official text
Source: FDA. Public domain.
Official text
Source: FDA. Public domain.
Official text
Source: MHRA. Contains public sector information licensed under the Open Government Licence v3.0.
Official text
Source: EMA.

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.