Tag: latam fih

  • Argentina And Colombia Just Signed A Regulatory Mou. Here’s What That Means For Medtech Sponsors Running Multi-Country LATAM Trials.

    The Headline

    On June 13, 2026, Argentina’s ANMAT (Administración Nacional de Medicamentos, Alimentos y Tecnología Médica) and Colombia’s INVIMA (Instituto Nacional de Vigilancia de Medicamentos y Alimentos) signed a Memorandum of Understanding that formalizes bilateral cooperation across medicines, food, and medical devices. The text was published on the INVIMA portal the same day. [INVIMA]

    For sponsors running, planning, or sequencing multi-country clinical programs in Latin America, this matters more than the typical regulatory press release. It is the most operationally consequential change to the Argentina-Colombia regulatory interface since 2018 — and it lands at the exact moment Colombia is finalizing its Decreto Único de Dispositivos Médicos and Argentina is operationalizing ICH E6(R3) Annex 2.

    This article walks through what the MoU actually establishes, what it does not establish, and how MedTech and Biopharma sponsors should sequence their LATAM trials in light of it.

    What The MoU Actually Says

    The June 13 instrument is short on legal flourish and dense on operational substance. Stripped to its four working pillars, the MoU establishes:

    1. Information exchange across regulated categories — covering registration dossiers, surveillance signals, and inspection findings.
    2. Protocol and best-practices sharing — methodologies, technical guidance, and procedural alignment on common review pathways.
    3. Joint project collaboration — coordinated capacity-building initiatives, training exchanges, and technical mission programming.
    4. Confidentiality and monitoring framework — formal governance of how shared data is handled and how cooperative activities are tracked over time.

    The cooperation explicitly covers medicines, food, and medical devices. That last category is the one many sponsors miss. The 2014 and 2018 instruments between the two agencies were narrower — 2014 focused on “exchange of experiences and good practices,” and 2018 was specifically about Good Manufacturing Practice inspection records. The 2026 MoU is the first comprehensive framework that unifies the medical device dimension with pharmaceuticals and food under a single working architecture. [ANMAT Cooperation Registry]

    What The MoU Does Not Do

    Three clarifications worth front-loading, because we are already seeing them misunderstood in early secondary commentary.

    The MoU does not create single-window approvals. A sponsor preparing a clinical trial in both Argentina and Colombia still files two separate dossiers, with two separate regulatory teams, on two distinct timelines. ANMAT continues to operate Disposición 7516/25 and the Resolution 1480/2011 ethics framework. INVIMA continues to operate under Decreto 4725 de 2005 and Resolución 1229 de 2013 until the new Decreto Único is published.

    The MoU does not formalize automatic reliance. Reliance — where one regulator can lean on another’s scientific assessment to shorten its own review — exists as a regulatory principle in both agencies’ modernization agendas, but the MoU itself does not create a reliance pathway between them. It creates the plumbing through which such pathways can later be built.

    The MoU does not change cost or fee structures. Sponsors should not expect this instrument to reduce regulatory review fees, ethics committee charges, or local sponsor representation costs in either jurisdiction.

    What It Does, In Practice

    What the MoU does, immediately, is formalize four operational improvements that previously depended on ad-hoc coordination through ICH Assembly hallway conversations and the International Pharmaceutical Regulators Programme (IPRP) plenary sessions.

    One. When a sponsor’s submission triggers a safety signal in one country, that signal can now flow through a structured channel to the other regulator within a defined confidentiality envelope. Before this MoU, a sponsor with a flagged adverse event in Argentina would typically receive an independent inquiry from Colombia weeks or months later, often duplicating the original investigation. After this MoU, the two regulators can coordinate the inquiry’s timing and scope.

    Two. Inspection of a sponsor or manufacturer operating in both jurisdictions can be coordinated. A single inspection mission, with two regulators present or with shared inspection reporting, materially compresses the sponsor’s compliance overhead.

    Three. Capacity-building and training activities — pharmacovigilance, tecnovigilancia, quality risk management — can be conducted jointly. This raises the technical floor in both countries, which is good for sponsors because the predictable downside of trial expansion to a smaller-budget regulator is technical inconsistency at the review level.

    Four. Standards and review methodologies can be aligned over time. The MoU does not specify which standards or methodologies, but it creates the working group structure to negotiate them. The most likely early candidates are software-as-a-medical-device classification, AI/ML model change pathways, and harmonization of IMDRF-aligned UDI requirements.

    The Decreto Único Context

    The MoU lands during one of the most active periods of Colombian medical device regulatory reform in two decades. Colombia’s Decreto Único de Dispositivos Médicos — a 16-chapter, 180-article instrument that consolidates and replaces Decretos 4725/2005 and 3770/2004 — completed its national public consultation phase and entered WTO international consultation on May 18, 2026. The comment window closes July 17, 2026. [CONSULTORSALUD]

    INVIMA’s Director of Medical Devices and Other Technologies, Doris Yolima Gómez Parada, has been publicly explicit about the substantive direction: indefinite-validity authorizations (conditioned on post-market performance), strengthened tecnovigilancia, mandatory Unique Device Identification (UDI) at initial registration, IMDRF-aligned risk classification (three classes expanding to four), and an explicit reliance framework that recognizes FDA, EMA, and ANVISA assessments — supplemented by Pacific Alliance, Rio Accord, and WHO Listed Authority qualifications.

    For a multi-country sponsor, the implication is direct: the Decreto Único modernizes Colombia’s regulatory architecture in ways that are structurally compatible with Argentina’s ICH E6(R3) Annex 2 adoption. The June 13 MoU is the procedural connective tissue between the two modernizations.

    The Argentina Side: ICH Annex 2 Operative

    Argentina entered this MoU from a position of unusual regulatory strength. ANMAT adopted the ICH E6(R3) operative framework under Disposición 7516/25, and Annex 2 — the risk-proportionate quality management addendum — was finalized to Step 4 at the ICH Assembly in Rio de Janeiro on June 3, 2026, two weeks before the MoU was signed. ANMAT confirmed participation in both the ICH Assembly and the IPRP sessions of June 3-4.

    Argentina’s documented FIH timeline benchmark currently sits at 62 days from study start to first patient enrolled, inclusive of ethics committee review, ANMAT regulatory authorization, and clinical site activation. That benchmark assumes a well-prepared sponsor working with operational sites in greater Buenos Aires, La Plata, Mendoza, and Rosario.

    The MoU’s value to an Argentina-primary sponsor is that secondary expansion into Colombia — historically a separate operational track with limited information continuity — now sits on a coordinated information channel. The Decreto Único’s reliance pathway, once operational, can in principle leverage Argentina-generated dossier work for parts of the Colombian submission.

    Practical Implications: How To Sequence A Multi-Country Trial Now

    For a MedTech, Biopharma, or Radiopharma sponsor planning a 2026-2027 LATAM trial, the operational sequencing question changes in three ways.

    Argentina-primary sequencing is now operationally cleaner. If your indication has equivalent patient availability in both Argentina and Colombia, starting in Argentina has three compounding advantages: ICH E6(R3) Annex 2 inspection-readiness, a 62-day study start timeline, and — under the MoU — a smoother information bridge into Colombia for the secondary expansion.

    Colombia is no longer a second-tier choice for sponsors with cardiovascular, oncology, or rare-disease indications. The combination of the MoU plus the Decreto Único’s reliance framework plus Colombia’s IMDRF affiliate member status (effective September 2025) materially raises Colombia’s strategic value. The five-month Colombian FIH timeline that has been the benchmark for the past three years will compress meaningfully once the Decreto Único is in force.

    The IRB and ethics committee dimension matters more, not less. The MoU does not touch independent ethics committee review. Sponsors gain little if their Argentine site is approved in 62 days and the Colombian ethics committee for a comparable indication takes four months. Operational selection of ethics committees with proven turnaround for the relevant therapeutic area becomes a larger fraction of the timeline gap.

    What To Watch Between Now And September

    Four watch items will determine how much of the MoU’s potential operational value crystallizes in 2026.

    July 17: The WTO comment window on the Decreto Único closes. Industry comment density and the substance of the final text will shape whether reliance is operationally meaningful or a paper provision.

    Late Q3 2026: Implementing language for the MoU. The instrument as signed is a framework. Working-group structure, the first joint technical projects, and any joint training program will signal how seriously both agencies intend to execute on the framework.

    Q4 2026: Decreto Único publication. The 18-month transition period for industry begins on publication. Sponsors should plan for a 2027 implementation horizon for the new Colombian regime.

    2027 onward: First coordinated inspection. If ANMAT and INVIMA execute a coordinated inspection of a sponsor or manufacturer operating in both countries, that becomes the case study that defines the MoU’s operational reality.

    Why This Matters For Operating At Scale In LATAM

    We have been operating multi-country clinical programs in Latin America since 2010. Across 47 first-in-human studies for MedTech, Biopharma, and Radiopharma sponsors, the practical bottleneck in expanding from a single-country trial to a regional program has rarely been regulatory text. It has been the discontinuities between regulators — different document formats, divergent timing assumptions, ethics committees that interpret international guidance differently, and the absence of any structured channel for coordinating safety information when a study runs in parallel in two jurisdictions.

    The MoU is the first instrument in our operating memory that addresses those discontinuities directly. It does not eliminate them. It builds the architecture inside which they can be addressed deliberately, instead of through ad-hoc coordination at ICH meetings.

    For sponsors evaluating LATAM right now, the immediate practical advice is: do not wait. The MoU’s value compounds for sponsors who establish operational presence in both Argentina and Colombia before the implementing language is in place — because those sponsors will be the test cases that shape how the MoU actually works. By the time the framework is mature, the operational advantage will have moved downstream.

    The Bottom Line

    The Argentina-Colombia MoU of June 13, 2026, does not change clinical trial regulation in either country. It changes the operating architecture between them. For multi-country LATAM sponsors, that architecture is the part of the regulatory environment that has been hardest to manage, and it is the part that has been most resistant to structural improvement.

    If your 2026-2027 strategic plan included evaluating LATAM as a multi-country option for an FIH or early-feasibility study, the case just got materially stronger. If your plan did not include LATAM, the regulatory ceiling that previously made multi-country expansion operationally difficult has been formally lifted.

    The two LATAM regulators with the deepest reform agendas in the region just connected their working architecture. The sponsors who move first will define what the connection means.


    bioaccess® is a clinical research organization purpose-built for first-in-human and early-phase studies for MedTech, Biopharma, and Radiopharma startups in Latin America. We have supported 47 FIH programs since 2010 across Argentina, Brazil, Colombia, Mexico, Costa Rica, and Panama. To discuss a multi-country LATAM trial strategy, contact us at info@bioaccessla.com or visit bioaccessla.com/roadmap.

  • ICH E6(R3) Annex 2 Just Hit Step 4 In Rio. Argentina Is Positioned To Be Latin America’s First Adopter. Here’s What That Means For Medtech Sponsors.

    On June 3, 2026, the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use convened its biannual Assembly in Rio de Janeiro — the first ICH meeting ever held in Latin America. Brazil’s health regulator, ANVISA, hosted. Among the multiple guidelines under consideration at the meeting, only one was advanced to Step 4 — the final stage of ICH adoption: E6(R3) Annex 2, the guideline that codifies decentralized clinical trial design, pragmatic study architectures, digital health technologies, and real-world data as integral elements of GCP-compliant clinical research.

    For a Latin American clinical research operator that has spent the past sixteen years arguing the case to MedTech, biotech, and radiopharma founders, the June 1 to June 4 sequence in Rio is the most strategically significant positioning event of 2026. The geographic precedent is itself meaningful — ICH governance has historically convened in Geneva, Brussels, Tokyo, or other established regulatory capitals. Selecting Rio de Janeiro and partnering with ANVISA as host signals a structural shift in how ICH governance views Latin American regulatory infrastructure. The substantive outcome — only one guideline elevated to Step 4 at the meeting, and that guideline being the one that defines modern trial design — matters even more for how sponsors will think about LATAM site sequencing over the next 18 to 24 months.

    This post unpacks what Annex 2 actually changes, why the Rio venue matters, and how MedTech sponsors should think about Argentina’s position as the first Latin American jurisdiction structurally ready to accept Annex 2-compliant protocols without amendment.

    What ICH E6(R3) Annex 2 Actually Changes

    ICH E6(R3) is the current Good Clinical Practice (GCP) guideline that all major regulators — FDA, EMA, MHRA, PMDA, Health Canada, and adopting regulators in Latin America — converge on for clinical trial conduct. The most recent revision moved GCP to a risk-based, principle-driven model. Annex 2 extends E6(R3) to explicitly cover the trial designs that have become operational reality over the past five years but lacked formal codification in GCP guidance.

    Specifically, Annex 2 addresses:

    • Decentralized clinical trials (DCTs) — trials where participant interaction with study sites is partially or fully replaced by remote visits, home-based assessments, mobile health units, or telehealth consultations.
    • Pragmatic trial designs — protocols built around real-world clinical settings, with broader patient populations and less restrictive inclusion criteria than traditional efficacy trials.
    • Remote site visits — sponsor monitoring conducted through electronic data review, remote source verification, and risk-based on-site oversight rather than universal in-person visits.
    • Digital health technology (DHT) data capture — continuous glucose monitors, wearable cardiac telemetry, accelerometer-based motion data, smartphone-based patient-reported outcomes, and similar tools used as primary or secondary endpoint capture methods.
    • Real-world data (RWD) — use of electronic health records, claims data, registries, and other non-trial sources as supporting evidence within GCP-compliant studies.
    • Adaptive designs — pre-specified protocol modifications based on accumulating trial data, including sample size re-estimation and arm-dropping decisions.

    The substantive shift in Annex 2 is not new regulation. It is the formal incorporation of these design elements into GCP rather than treating them as exceptions that require special justification. For sponsors who have been building modern trial designs over the past five years, the legal architecture finally caught up with the operational reality.

    Why The Rio Venue Matters

    ICH Assembly meetings rotate among the home jurisdictions of ICH members. Hosting the meeting is a substantive role — the host regulator coordinates logistics, sets the agenda for site-specific discussions, and shapes the framing of how the meeting’s outcomes are communicated to global stakeholders. ANVISA hosting the June 2026 Assembly is the strongest signal to date that Brazilian regulatory infrastructure is converging with ICH governance not as an observer but as an active participant.

    For Brazilian sponsors and CROs, the immediate implication is that ANVISA’s preparation for formal E6(R3) adoption is now visible in a way it was not six months ago. The May 28, 2026 ANVISA board session that explicitly addressed ICH E6 and E8 implementation preparation was the first concrete signal. The June 3 Assembly hosting is the next, much stronger signal. Brazilian formal E6(R3) adoption has no publicly announced timeline yet, but the operational trajectory is no longer in doubt.

    For Argentina, the implication is different but equally substantive. Argentina’s ANMAT, under Disposición 7516/25 operative since December 1, 2025, already maintains a regulatory framework aligned with E6(R3) principles. Argentina did not need to host the Rio Assembly to be ready for Annex 2 — it was already there. What the Rio Assembly does for Argentina is confirm that its regulatory positioning was correctly anticipated, and accelerate the speed at which ANMAT can absorb Annex 2-aligned protocols from sponsors.

    Argentina As The First LATAM Annex 2-Ready Jurisdiction

    Disposición 7516/25 modernized Argentina’s clinical trial framework along several dimensions that align directly with E6(R3) principles: a 62-day parallel ethics and agency review pathway, ICH E6(R3) substantive alignment in protocol structure expectations, and operational mechanisms for risk-based monitoring and remote oversight. Critically for Annex 2, Disposición 7516/25 does not preclude decentralized design elements, DHT data capture, or pragmatic patient populations — it accommodates them.

    The practical consequence is that sponsors designing Annex 2-compliant protocols for FDA or EMA submission in 2026 and 2027 do not face a structural barrier to LATAM site inclusion when Argentina is the lead LATAM jurisdiction. Brazil, Colombia, Mexico, and other LATAM regulators have not formally adopted E6(R3), let alone Annex 2 — meaning protocols built around decentralized or DHT-enabled designs face higher regulatory friction in those jurisdictions until each regulator adopts the guidance domestically.

    For Brazil, the trajectory is unambiguous post-Rio. ANVISA hosting the Assembly, the May 28 board session on E6 and E8 preparation, and the substantive operational alignment between ANVISA’s technovigilance and clinical research frameworks all point toward formal E6(R3) adoption in 2026 or 2027. Annex 2 acceptance follows.

    For Mexico (COFEPRIS), Colombia (INVIMA), and other LATAM regulators, the path is less defined. Colombia’s pending Decreto Único de Dispositivos Médicos e In Vitro (currently in WTO comment phase with a July 17 deadline) introduces international reliance pathways that may indirectly accelerate Annex 2 acceptance, but no formal adoption has been signaled.

    Operational Implications For MedTech Sponsors Designing 2026-2027 Protocols

    For a MedTech sponsor designing a protocol today for a 12 to 18 month FIH-to-pivotal sequence, three operational questions matter immediately.

    First, should the protocol be built Annex 2-compliant from the start? The answer is almost always yes if any of the following apply: DHT-collected endpoints are part of the endpoint set; the patient population is large enough that pragmatic design considerations would materially expand enrollment; remote visits or telehealth consultations would meaningfully reduce participant burden; or the trial design contemplates pre-specified adaptive elements such as sample size re-estimation. Building Annex 2-compliant from the start adds modest protocol-authoring effort and substantial future flexibility.

    Second, how should LATAM country sequencing change? For 2026 and through Q2 2027, Argentina-primary is now the recommended LATAM lead jurisdiction for any Annex 2-aligned design. Disposición 7516/25 is the only operative LATAM framework that can absorb the design without amendment. Brazil-secondary is appropriate as ANVISA formalizes its adoption. Mexico and Colombia remain opportunistic, evaluated on therapeutic-area depth and sponsor-specific operational requirements rather than as primary LATAM hubs for decentralized designs.

    Third, what about sponsors with existing LATAM site relationships built around traditional trial architectures? The Annex 2 guidance does not invalidate traditional trial designs. Sponsors running fully on-site, non-decentralized protocols can continue without adjustment. The shift matters for sponsors whose product strategy is built around DHT-collected endpoints or decentralized data capture — for whom the regulatory architecture in LATAM was previously a bottleneck and now is not.

    What Comes Next

    National regulator implementation of E6(R3) Annex 2 will proceed on independent timelines through 2026 and 2027. FDA has signaled implementation guidance is forthcoming. EMA has indicated alignment without formal adoption schedule. PMDA and Health Canada are expected to follow. In Latin America, ANMAT is positioned to be the first formal adopter, followed by ANVISA. The realistic timeline for ANMAT formal Annex 2 acceptance is Q4 2026 to Q1 2027. ANVISA follows in H1 2027 to H2 2027.

    For sponsors making 2026 country sequencing decisions today, the implication is straightforward. Argentina is positioned as the natural lead LATAM jurisdiction for Annex 2-aligned protocols. Brazil follows. Mexico and Colombia continue to be evaluated case-by-case based on therapeutic-area depth and sponsor-specific requirements.

    The Bottom Line

    Latin America is no longer at the edge of global GCP. The June 3 Rio Assembly, the ANVISA hosting of the meeting, and the Step 4 advancement of E6(R3) Annex 2 together signal a structural shift that sponsors building modern trial designs should integrate into 2026-2027 strategy now rather than after the fact.

    The most expensive country sequencing decision is not the one made wrong. It is the one made too late, after the trial design has been frozen and the regulatory pathway is already constrained by choices that no longer reflect the current landscape.

    If you are evaluating an Annex 2-aligned FIH protocol for 2026 or 2027 and want a LATAM country sequencing analysis that integrates the new Rio Assembly outcomes, the team at bioaccess® can produce a tailored proposal within two weeks. We have run first-in-human and pivotal-stage trials across Argentina, Brazil, Colombia, Mexico, and Panama since 2010, and our U.S. EFS plus LATAM FIH practice is the only one in Latin America structured to deliver both pathways under a single operational team.

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