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

EMA GMP Questions and Answers: Annex 11 and Data integrity

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

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Questions and answers from EU inspectors explaining how they read Annex 11 and data integrity in practice.

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 · ~1 Feb 2011Annex 11 questions dated February 2011

In plain English

EMA questions and answers on applying EU GMP. The Annex 11 section covers spreadsheets, database security, validation and storage of electronic data. The data integrity section covers data risk, the data lifecycle, audit trails, review of electronic data, ALCOA and supply chains.

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

Context and history

These are sections of the EMA and EU inspectors' long-running questions and answers on GMP and GDP. The Annex 11 questions are dated February 2011, and the Data integrity section has 23 questions with no date shown. They explain how inspectors read Annex 11 and data integrity in practice.

Who and what it applies to

Manufacturers, importers and others under EU GMP, including senior management, contract givers and acceptors, and Qualified Persons.

What it contains

Annex 11 questions
Spreadsheets, database security, risk management across the lifecycle, retrospective validation of legacy systems, revalidation, electronic data storage time, small devices and printouts.
Data risk and criticality
How to assess each, including what decision the data influence and their impact on quality or safety.
Data lifecycle
What it means, why it matters, and what to consider when reviewing it.
Data integrity procedures and paper control
Whether a specific procedure is required, and how to control paper systems against unauthorised re-creation of data.
Electronic data
How to preserve originals, why to review electronic data, and whether risk-based review is acceptable.
Self-inspection and contracting
Self-inspection, contract activities, building confidence in certificates of analysis, and supply chain responsibility.

Key points

  • Spreadsheets are in scope and need controls.
  • Data integrity failures at contractors matter to the contract giver.
  • Review of electronic data should be risk-based, and exception-based review has conditions.

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.

  • Add these to your procedures' references, as they show inspectors' current reading.
  • Use the data criticality questions in a structured review of your systems.
  • Check your paper controls against the unauthorised re-creation question.

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
1 Nov 2026Data integrity section (23 questions) listed; no date shownFinalSource for Data integrity section (23 questions) listed; no date shown
~1 Feb 2011Annex 11 questions dated February 2011FinalSource for Annex 11 questions dated February 2011

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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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