EMA · Life Science & Pharma: GxP - CSV & Data Integrity

Guideline on computerised systems and electronic data in clinical trials

Final CSV & Data Integrity · Guideline Last verified: not yet · Source last checked 3 Nov 2026

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EMA's guideline on computerised systems and electronic data in clinical trials, such as audit trails, cloud services and vendor agreements.

How to read this page

Details: Guide Definitions: every term and label explained

Lifecycle

Solid steps have happened. A dashed step is expected, and it is not a fact. Only dated steps in our record appear here.

  1. Done · 18 Jun 2021Public consultation started
  2. Done · 17 Dec 2021Public consultation closed
  3. Done · 7 Mar 2023Final version adopted by the GCP Inspectors Working Group
  4. Done · 10 Mar 2023Final version published

In plain English

EMA guideline for clinical trials on computerised systems and electronic data. It covers data integrity, responsibilities, validation, audit trails, user management, security, data migration and archiving, and it includes artificial intelligence. It replaced the 2010 reflection paper on electronic source data.

Summary drafted with AI assistance. Not yet reviewed by the SME Reviewer. Read the official text before acting.

Context and history

This EMA guideline sets expectations for computerised systems and electronic data in clinical trials. Its consultation ran from 18 June to 17 December 2021, and the GCP Inspectors Working Group adopted the final version on 7 March 2023. It replaced the 2010 reflection paper on electronic source data. It took effect six months after publication.

Who and what it applies to

Sponsors, investigators, service providers and others using computerised systems in clinical trials.

What it contains

Principles
Data integrity, responsibilities, data and metadata, source data, criticality and risk, data capture, electronic signatures, data protection and validation.
Computerised systems
Description, procedures, training, security and access control, and timestamps.
Data
Capture, audit trail and its review, sign-off, copying, certified copies, control of data, cloud solutions, backup, contingency, migration, archiving and decommissioning.
Annexes
Agreements, computerised systems validation, user management, security, and specific systems including AI.

Key points

  • Audit trail review is expected, and metadata review can extend to access logs, event logs and queries.
  • Investigators should be shown how to navigate audit trails for their own data.
  • Investigators are responsible for data entered under their supervision, and sign-off is confirmation at set milestones.
  • Agreements with service providers are needed.
  • Cloud solutions, migration and decommissioning are addressed.

In practice

General reading, not advice. This is drafted with AI and may not fit your situation. It does not replace the official text, your own quality system or qualified advice, and an inspector may take a different view.

  • Check that vendor qualification covers cloud and eCOA providers.
  • Plan decommissioning and data access before a trial starts.
  • Train investigators on audit trail access, as the guideline expects.

Read from the source document on 1 Nov 2026. This is our own description, not the official text. Check the full dated history in the change log below.

Change log

Key dated events only, not a complete history. Status after is the status once that event happened. Event kinds explained

DateEventStatus afterSource
10 Mar 2023Final version publishedFinalSource for Final version published
7 Mar 2023Final version adopted by the GCP Inspectors Working GroupFinalSource for Final version adopted by the GCP Inspectors Working Group
17 Dec 2021Public consultation closedDraftSource for Public consultation closed
18 Jun 2021Public consultation startedDraftSource for Public consultation started

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Official source

The official text always prevails over anything on this site.

Read the official text

Source: EMA. Summary adapted from the original.

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