EU Legal Representative
Frequently Asked Questions

Basics of EU Legal Representation

What is an EU Legal Rep?

An EU Legal Representative is a person or organization established in the European Union who acts on behalf of a non-EU sponsor under European Clinical Trial Regulation (CTR) 536/2014 Article 74. This representative is legally accountable for sponsor responsibilities within the EU and serves as the sponsor's point of contact for regulators.

Why do I need a EU Legal Rep?

If your company is based outside the EU and you're planning to run a clinical trial in one or more EU member states, you're legally required under CTR Article 74 to appoint an EU Legal Representative. Without one, your CTIS submission will be rejected.

Is there a formal approval process for the legal representative?

No. The legal rep is not approved separately by authorities. Instead, the signed representation letter is reviewed as part of your clinical trial application in CTIS. Your rep must also be registered in EMA’s OMS and properly assigned in CTIS.

Why should I avoid hiring my CRO to satisfy the legal rep requirement?

Appointing your CRO as your EU Legal Rep creates a conflict of interest and limits regulatory oversight. An independent legal rep protects your interests, ensures transparency, and strengthens compliance under CTR Article 74—while also making it easier to switch CROs if needed, without disrupting your regulatory setup.

Pricing & Contracts

What is your refund policy?

You’re eligible for a full refund within 14 days of contract signing, as long as onboarding hasn’t begun. Once we’ve started reviewing your documents, fees are non-refundable due to the high-touch nature of the service.

Do you offer discounts for multiple trials?

Yes. We offer custom pricing and discounts for sponsors running multiple concurrent or sequential trials. Bundled onboarding and advisory packages are available.

Are there long-term contracts?

No. Our standard pricing is fixed for the first year of trial coverage, with monthly billing available after year one. There are no long-term commitments, and multi-trial or multi-year discounts are available upon request.

Can I upgrade or switch plans later?

Yes. You can upgrade from a lower-tier plan at any time. We’ll apply your existing payment toward the new tier and adjust services accordingly.

Are there any additional fees?

Our pricing is fixed-fee, with no hidden costs. Add-on services like hourly regulatory consulting, CTIS submission, or SOP template customization are available for an additional charge and clearly quoted upfront.

Onboarding & Setup

How long does it take to get the EU Legal Rep service set up?

Most sponsors get fully covered within 14 days. This includes document review, contract signing, and delivery of the signed EU Rep Letter—assuming prompt sponsor responses.

What happens after I pay?

You’ll receive an onboarding email with a secure intake form. Once we receive your documents, we begin review and scheduling—typically issuing your legal rep letter within 14 days.

What happens after I receive the EU Legal Rep Letter?

Once the letter is signed, we can assist with uploading it to CTIS, confirm OMS registration, and ensure our role is properly assigned in the system—minimizing back-and-forth and getting you Article 74–ready faster.

Documentation & Review

What documents do you need from us before issuing the EU Rep Letter?

We’ll ask for: your trial protocol (latest draft), sponsor legal entity details, indemnity insurance certificate, contact information for key sponsor reps, (optional) CTIS/OMS registration details and PI list.

What do you check during document review?

We verify: sponsor eligibility under Article 74, entity name and address consistency, sufficient insurance coverage, CTIS/OMS readiness, and any red flags in the protocol.

What happens if something is missing or unclear?

We’ll notify you within 1–2 business days. Common issues include incomplete insurance documentation, mismatched sponsor details across the protocol and OMS, or a lack of registration in CTIS. We aim to resolve most issues in a single round of clarification to keep your trial startup on schedule.

How long does the review take?

Typical turnaround is 1–3 business days, depending on how quickly you respond to clarification requests. Once your documentation is approved, we proceed to contract and rep letter finalization.

Service Details

What does your service include?

Our standard service includes: a CTR-compliant EU Legal Representative Letter, use of our Prague-based legal address, regulatory inbox setup and monitoring (e.g., CTIS), a 60-minute onboarding call, and structured support—all managed through a secure client dashboard.

Are you compliant with ICH-GCP?

Yes. Our services are aligned with Good Clinical Practice (ICH-GCP) standards, and our team is trained in GCP oversight and sponsor compliance obligations.

What’s included in the online dashboard?

The dashboard includes a document repository, task tracker, CTIS inbox alerts, and milestone status—all in one secure workspace. It also provides an audit trail and ensures alignment across your team without relying on email.

How do add-ons work?

Add-ons like hourly regulatory consulting, CTIS submission support, drafting support for regulator information requests, or SOP template customization can be selected during onboarding or added later. We’ll provide clear pricing and scope before activation—no surprises.

SME Status

What are the benefits of EMA SME status?

SME status grants fee reductions, extended payment deadlines, procedural assistance, and access to dedicated support from the SME Office.

Who qualifies for SME status?

To qualify for EMA SME status, a company must be legally established in the EU or EEA and meet the EU definition of a micro, small, or medium-sized enterprise—fewer than 250 employees and either ≤ €50M turnover or ≤ €43M balance sheet total.

Ownership structure matters: if you're partnered with or owned by larger firms, their financials may count against your eligibility.

Non-EU sponsors can apply via an EU-based legal representative like AAYT.

What documents are required to apply for SME status?

You’ll need proof of company size, legal establishment in the EU/EEA, and supporting financial statements (or a self-certification for early-stage startups).

Can non-EU companies apply for SME status?

Only companies established in the EU or EEA are eligible, but a legal representative like AAYT—or an EU/EEA-based subsidiary—can apply on behalf of non-EU sponsors.

How long does SME status approval take?

Typically 1–2 weeks once a complete application is submitted to the EMA SME Office.

Is SME status required for early access or accelerated programs?

Not required, but SME status improves access to tools like PRIME, adaptive pathways, and EMA innovation support.

Is SME status permanent?

No. It must be renewed annually to ensure continued compliance with eligibility criteria.

Does AAYT help with SME status applications?

Yes. We provide eligibility checks, documentation review, and act as your EU Legal Representative if needed for the application.

Orphan Drug Designation (ODD)

What is Orphan Drug Designation (ODD)?

ODD is a special regulatory status granted by the EMA for therapies targeting rare diseases—offering sponsors incentives like reduced fees, market exclusivity, and protocol assistance.

Who qualifies for Orphan Drug Designation in the EU?

Any sponsor developing a therapy for a life-threatening or chronically debilitating rare condition (affecting ≤5 in 10,000 people in the EU) may be eligible.

Can non‑EU companies apply for ODD?

Yes—non‑EU sponsors can apply as long as they have a legal representative established in the EU or EEA. AAYT provides EU Legal Representative services.

What are the main benefits of ODD?

Reduced regulatory fees, 10-year market exclusivity, early scientific advice from EMA, and eligibility for accelerated evaluation pathways.

How long does the EMA take to decide on ODD?

The EMA typically issues a decision within 90 days of a valid application submission.

What documents are required for ODD submission?

Core requirements include a description of the condition, prevalence estimates, and evidence of medical plausibility and benefit.

Do I need clinical data to apply for ODD?

Not necessarily—preclinical or compelling nonclinical evidence may be sufficient if it supports the product’s potential benefit.

Can I apply for ODD and CTA (Clinical Trial Application) at the same time?

Yes. Many sponsors pursue ODD designation in parallel with early-phase trial planning under the CTR.

What happens after my product is granted ODD?

You'll gain access to fee reductions, dedicated EMA protocol support, and potential entry into PRIME or other fast-track pathways.

Can AAYT support the full ODD application process?

Yes. AAYT helps with eligibility review, dossier preparation, submission coordination, and communication with EMA throughout the process. We also provide required EU Legal Representative services.

PRIME Designation

What is PRIME designation from the EMA?

PRIME is an EMA program that offers early regulatory support for therapies addressing unmet medical needs. It provides scientific advice, dedicated contacts, and potential accelerated review—helping sponsors with promising early data speed up EU development.

What are the benefits of PRIME Designation?

Early interaction with EMA, dedicated support from a rapporteur, and eligibility for accelerated assessment at the time of Marketing Authorisation Application (MAA).

Who qualifies for PRIME?

Sponsors with therapies that show early clinical evidence of addressing an unmet medical need—especially in serious or life-threatening conditions.

Do I need clinical data to apply for PRIME?

Yes—at minimum, compelling preliminary clinical data (typically from Phase I or early Phase II) is expected to support your application.

Can non-EU sponsors apply for PRIME?

Yes. Non-EU sponsors can apply, but they must have an EU Legal Representative named and comply with EMA submission procedures.

When should I apply for PRIME?

As early as possible once you have promising clinical data—ideally before initiating pivotal trials and before formal scientific advice requests.

Is PRIME only for rare diseases or orphan drugs?

No. While many PRIME products also have ODD, PRIME is open to any therapy that shows transformative potential for unmet needs.

Can PRIME help speed up EMA approval?

Yes. PRIME can lead to accelerated assessment (150 days vs. 210) and earlier guidance that improves your development plan.

What does the PRIME application include?

A cover letter, justification for unmet need, summary of clinical data, and a development plan showing benefit over existing options.

What happens after a PRIME request is accepted?

Quickly and efficiently build the materials you need to support your inbound marketing strategy. Drag and drop building blocks including testimonials, forms, calls-to-action, and more.

Can AAYT support the full PRIME submission process?

Yes. AAYT provides eligibility assessment, application strategy, dossier review, submission coordination, and ongoing regulatory support. We also provide required EU Legal Representative services.

Schedule a Regulatory Advisory Session

We’ll help you assess your readiness to appoint an EU Legal Representative, answer your questions, and explore your eligibility for EU incentives for small and medium-sized businesses, promising new medicines, and treatment of rare diseases.

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