AI in-drug development: U.S. and EU regulatory perspectives
Artificial intelligence creates new opportunities for data analysis, clinical trial optimization and improving manufacturing processes, potentially transforming pharmaceutical development and production. Both the United States and the European Union have recently advanced their regulatory frameworks to address the unique challenges and risks posed by AI in the medicinal product lifecycle.
Reflecting a harmonized approach to AI oversight in drug development, FDA has collaborated with EMA to articulate ten guiding principles. Released in January 2026, the "Guiding Principles of Good AI Practice in Drug Development" are designed to ensure AI use remains ethical, transparent, and reliable across the drug lifecycle – from research to post-marketing. These principles emphasize human-centric design, risk-based oversight, adherence to standards, robust data governance, and clear communication. They also call for multidisciplinary expertise, rigorous model development, and continuous performance monitoring. By fostering international collaboration and harmonized standards, these guidelines aim to advance responsible AI adoption while safeguarding patient health and regulatory integrity, complementing the steps that the EMA and FDA are each taking to foster and regulate AI-based innovation.
Blockchain, meanwhile, offers the ability to store and transmit data in a decentralized and real-time manner. Blockchain could help resolve many ATMP supply chain challenges due to its inherent characteristics of: (i) consensus; (ii) provenance and immutability; (iii) finality; (iv) security and reliability; and (v) decentralization. Blockchain transactions are secure, authenticated and verifiable. This is relevant to ATMPs because:
U.S. FDA's Risk-Based Guidance
FDA's 2025 draft guidance on the use of AI in regulatory decision-making for drugs and biologics introduces a comprehensive, risk-based framework for sponsors, emphasizing model credibility, transparency, and lifecycle management. Key elements include a seven‑step process covering AI model risk and credibility assessments, required credibility assessment plans and reports, and continuous oversight through lifecycle maintenance plans. Notably, FDA's guidance applies to nonclinical, clinical, postmarketing, and manufacturing phases, but excludes AI used solely for drug discovery or operational efficiencies that do not impact patient safety or data reliability. Early FDA engagement is strongly encouraged.
In parallel, FDA has embraced AI as an internal agency tool under the current Commissioner, announcing its adoption of agentic AI for premarket review, review validation, post-market surveillance, meeting management, and for inspections and compliance purposes, as well as administrative functions.
Authors
Jason F. Conaty
Counsel Global Regulatory Washington, D.C.Los Angeles
EMA's Guideline Development
In 2024, the EMA published a reflection paper, providing guidelines for the use of AI throughout the medicinal product lifecycle, including drug discovery, clinical trials, manufacturing, and post-authorization, with a focus on patient safety and bias mitigation. The adopted guideline emphasizes a risk-based approach, robust governance, data integrity, transparency, and ethical oversight, in line with EU laws like the AI Act and GDPR.
To further advance the use of AI in medicines regulation, the EMA established the Network Data Steering Group with a 2025-2028 workplan designed to enhance EU medicines regulation by optimizing data use and interoperability, strengthening analytics and real-world evidence capabilities, and leveraging AI to support faster, safer, high quality regulatory decision making at the EMA.
EMA and FDA's Harmonized Approach to AI Oversight
The ten Guiding Principles of Good AI Practice underline these policy initiatives being taken by each agency separately. They make clear that quality system regulation and good manufacturing practice will be applied to AI in drug and biological product development, with risk-based quality management systems to be implemented throughout the AI technologies' lifecycle. Early engagement with regulators is emphasized to ensure compliance with fast-evolving standards.




