Important information about clinical trials, including advice relating to COVID-19, is available on the Department of Health's Australian clinical trials website.
Clinical trial processes - Information relating to COVID-19 provides clarification about the clinical trial process as it relates to COVID-19.
Clinical trials conducted in Australia are subject to various regulatory controls to ensure the safety of participants. We regulate the use of therapeutic goods supplied in clinical trials in Australia under the therapeutic goods legislation.
Good Clinical Practice Inspection Program
Clinical trials of medicines and biologicals regulated under the CTN or CTA schemes are subject to the TGA's Good Clinical Practice (GCP) Inspection Program.
The TGA has published guidance on the Good Clinical Practice (GCP) Inspection program to provide sponsors with further information about the program's scope and process.
Clinical trial sponsors must be aware of the requirements to import, export, manufacture and supply therapeutic goods in Australia.
The following avenues provide for the importation into and/or supply in Australia of 'unapproved' therapeutic goods for use in a clinical trial:
- Clinical Trial Notification (CTN) scheme; and
- Clinical Trial Approval (CTA) scheme.
Clinical trials that do not involve 'unapproved' therapeutic goods are not subject to requirements of the CTN or CTA schemes. It is the responsibility of the Australian clinical trial sponsor to determine whether a product is considered an 'unapproved' therapeutic good.
Information about clinical trials for consumers, health care providers, researchers, industry and sponsors is available on the National Health and Medical Research Council's Australian clinical trials website.
CTN Scheme
The CTN Scheme is a notification process involving the following:
- The Australian clinical trial sponsor must notify us of the intent to sponsor a clinical trial involving an 'unapproved' therapeutic good. This must take place before starting to use the goods. The notification form must be submitted online and accompanied by the relevant fee.
- We may give the sponsor of the trial written notice to provide specified information relating to goods notified in the CTN form.
- We do not evaluate any data relating to the clinical trial at the time of submission. The Human Research Ethics Committee (HREC) reviews the scientific validity of the trial design, the balance of risk versus harm of the therapeutic good, the ethical acceptability of the trial process, and approves the trial protocol. The HREC is also responsible for monitoring the conduct of the trial.
- The institution or organisation at which the trial will be conducted, referred to as the 'Approving Authority', gives the final approval for the conduct of the trial at the site, having due regard to advice from the HREC.
- It is the responsibility of the sponsor to ensure that all relevant approvals are in place before supplying the 'unapproved' therapeutic goods in the clinical trial.
Under the Australian regulatory framework for biologicals certain Class 4 biologicals are not able to be supplied under the CTN Scheme and must be submitted under the CTA scheme.
CTN form
The online CTN form can be accessed via the TGA business services website.
For step-by-step instructions on how to obtain access to this form and submit a CTN, see the CTN form - user guide.
The CTN Scheme transitioned from paper-based applications to an online submission process on 1 July 2015. If a CTN has not been migrated to the new online portal, please contact the clinical trials team at clinical.trials@health.gov.au.
CTA Scheme
We are currently in the process of reviewing the CTA Scheme. More information at Review of Clinical Trial Approval Scheme.
The CTA Scheme is an approval process involving the following:
- A sponsor submits an application to us seeking approval to supply 'unapproved' therapeutic goods in a clinical trial. The application must be accompanied by the relevant fee.
- We evaluate summary information about the product including relevant, but limited, scientific data (which may be preclinical and early clinical data) prior to the start of a trial.
- The HREC is responsible for considering the scientific and ethical issues of the proposed trial protocol.
- The sponsor must notify us of each trial conducted using the 'unapproved' therapeutic good(s) approved in the CTA application.
If you are considering submitting a CTA application, you are strongly encouraged to contact us for advice regarding the application process.
CTA forms
The CTA forms can be accessed via CTA scheme forms.
Clinical trials guidance
We have published the Australian clinical trial handbook to provide guidance to clinical trial sponsors, Human Research Ethics Committees (HRECs), investigators and approving authorities (institutions).
The following guidelines are also relevant to clinical trials conducted under the CTN and CTA schemes:
- ICH Guideline for Good Clinical Practice with TGA annotations
- National Statement on Ethical Conduct in Human Research (National Statement) issued by NHMRC
- Note for guidance on clinical safety data management: definitions and standards for expedited reporting
- The NHMRC Guidance: Safety monitoring and reporting in clinical trials involving therapeutic goods
The Which clinical trial scheme should I choose? tool helps Australian trial sponsors determine whether the CTN or the CTA scheme is most appropriate for a clinical trial.
The Clinical Trial Notification (CTN) form: user guide has been created to provide information on how to access and use the online clinical trial notification (CTN) form. It provides step-by-step guidance on how to access TGA Business Services, create a new CTN, submit the CTN and make payment. You will also learn how to edit, save, validate, print and check the status of your submission.
We have also published several videos explaining the online CTN form.
- Video 1: Creating and submitting a Clinical Trial Notification (CTN)
- Video 2: Invoicing and the role of the Clinical Trials Repository
FAQs
In this section: General | Sponsor information | Online CTN form | Submitting and printing | Fees, invoices and payments | Import, export and labelling | Medicinal cannabis
General
What is an 'unapproved' therapeutic good?
An 'unapproved' therapeutic good for the purposes of the CTN and CTA schemes includes:
- any medicine not included in the Australian Register of Therapeutic Goods (ARTG), such as any new formulation, strength or size, dosage form, name, indications, directions for use or type of container of a medicine already in the ARTG
- any medical device (including an in vitro diagnostic device (IVD)) not included in the ARTG, such as any new sponsor, manufacturer, device nomenclature system code, classification or unique product identifier (for certain classes of medical devices only) of a medical device already in the ARTG
- any in-house IVD medical device, used for the purpose of a clinical trial, where the laboratory providing the in-house IVD is unable to comply with the regulatory requirements for in-house IVDs
- any biological not included in the ARTG such as:
- any new applicable standards, intended clinical use or principal manufacturer of a Class 1 or 2 biological already in the ARTG
- any new product name, dosage form, formulation or composition, therapeutic indication, type of container or principal manufacturer of a Class 3 or 4 biological already in the ARTG
- therapeutic goods already included in the ARTG to be used in a manner not covered by the existing entry in the ARTG.
Should I submit a CTN or a CTA?
The TGA administers two pathways for clinical trials, the Clinical Trials Notification (CTN) and Clinical Trials Approval (CTA) schemes. These provide an avenue through which 'unapproved' therapeutic goods may be lawfully supplied for use solely for experimental purposes in humans.
The choice of which route to use (CTN or CTA) lies firstly with the Australian clinical trial sponsor and then with the Human Research Ethics Committee (HREC) that approves the protocol.
The CTA route is generally designed for high-risk or novel treatments where there is no or limited knowledge of safety. For medical device trials, the CTA scheme may be more appropriate where the experimental device introduces new technology, new material or a new treatment concept which has not been evaluated previously in clinical trials in any country. The CTA scheme should also be considered for medical devices that pose a risk of serious patient harm.
The determining factor for an HREC is whether the committee has access to appropriate scientific and technical expertise in order to assess the safety of the product.
However, under the Australian regulatory framework for biologicals certain Class 4 biologicals are not able to be supplied under the CTN Scheme and must be submitted under the CTA scheme.
For assistance in determining whether the CTN or the CTA scheme is most appropriate for a clinical trial, please see Which clinical trial scheme should I choose?.
When do I submit clinical trial completion advice?
Sponsors should notify us of trial completion once the clinical trial-related activity afforded by a CTN exemption or CTA approval is no longer required. It is, however, the responsibility of the sponsor to determine when the exemption or approval is no longer required. Notification of completion of a clinical trial should be made only after the trial has been completed at all sites. It is not necessary to notify completion dates for individual trial sites.
The online CTN should be used to submit a completion advice to us. Please refer to the Clinical trial notification (CTN) form: User guide for further information.
Sponsor information
Who can be the clinical trial sponsor under the CTN/CTA schemes?
The sponsor of a trial can be an individual, company, institution, or organisation which takes responsibility for the initiation, management, and/or financing of a clinical trial.
The type of sponsor will vary from trial to trial, depending on who takes overall responsibility for the conduct of the trial. If the investigator initiates and organises the trial, he or she is defined as the sponsor of the trial and will be responsible for the sponsor's functions.
The sponsor of the trial must be a legal Australian entity. An overseas company, person or entity, for the purpose of the Australian legislation, is not the 'sponsor' of the trial in Australia.
The Australian clinical trial sponsor is responsible for submitting the CTN or CTA.
What do the clinical trial sponsor's responsibilities include?
The clinical trial sponsor's responsibilities in relation to Good Clinical Practice (GCP) are set out in section 5 of the ICH Guideline for Good Clinical Practice with TGA annotations. The clinical trial sponsor must also comply with the requirements of the therapeutic goods legislation as well as any other Commonwealth or state/territory legislation in relation to clinical trials and the supply of therapeutic goods.
The Australian sponsor of a clinical trial is also responsible for safety reporting. The guidance document Safety monitoring and reporting in clinical trials involving therapeutic goods addresses safety monitoring and reporting requirements for investigational products in Australia.
Can a clinical trial sponsor delegate responsibilities?
A sponsor may transfer any or all of the sponsor's trial-related duties and functions, including adverse drug reaction reporting, to a Contract Research Organisation (CRO). However, please note that the ultimate responsibility resides with the trial sponsor.
Online CTN form
How do I access the online CTN form?
To submit CTNs online, you will need access to our secure online TGA Business Services (TBS) site. This applies to organisations that already have a TGA client identification number (Client ID), as well as new organisations.
If your organisation:
- already has a TGA client ID and online access to TBS - please see your organisation's TBS administrator who can add you as a user.
- has a TGA Client ID without online access to TBS - please nominate an administrator via the Organisation details form to gain online access to TBS.
- does not have a TGA Client ID - go to TGA Business Services: Getting started with the TGA for information and forms to obtain a new Client ID and online access to TBS.
Additional information for using the TBS site can be found at TGA Business Services - How to use the site. Any further questions can be directed to the TBS Helpdesk at ebs@tga.gov.au or 1800 010 624.
Is there a user guide to assist me in completing the CTN form?
We have provided a step-by step Clinical Trial Notification (CTN) form: User guide.
If you experience any difficulties using the online CTN form, please contact the clinical trials team at clinical.trials@health.gov.au or contact us.
How do I make changes to an online CTN form that has been submitted?
If you have prematurely submitted a CTN and need to correct administrative errors, you may request that we 'push-back' the notification. Such requests should be sent via email to the clinical trials team at clinical.trials@health.gov.au.
If any details of your trial have changed after the CTN has been processed, you need to submit a variation using the online portal. See the Varying trial details section of the Clinical Trial Notification (CTN) form: User guide for further information.
Please note that certain variations to a previously notified CTN incur a fee.
What changes need to be notified to the TGA?
Any changes to details notified in the online CTN form should be updated and submitted to us. See the Varying trial details section of the Clinical Trial Notification (CTN) form: User guide for guidance on how to vary your online CTN.
How long will it take for the TGA to process a CTN?
The target time to process online CTNs is 5-7 working days; however we endeavour to process the notification as soon as possible. Please note that this timeframe does not include the time taken for TGA finance to match the payment (if required) to your submission.
You can track the status of your CTN by logging onto the TBS online portal. Refer to the section How to check the status of your CTN in the Clinical Trial Notification (CTN) form: User guide.
Can I submit an online CTN form prior to approval from the Human Research Ethics Committee (HREC)?
We will accept CTN form submissions while the sponsor is obtaining the necessary endorsements. However, it is the responsibility of the sponsor to ensure that all relevant approvals are in place before commencement of the trial.
We encourage all parties to be in agreement as to when the CTN form should be submitted.
The therapeutic goods legislation requires that the trial be run with appropriate governance in place and in accordance with the ICH Guideline for Good Clinical Practice (GCP) with TGA annotations. Section 8.2 of these guidelines outlines the documents and signed agreements that should be on file before the clinical phase of the trial commences.
The clinical trial sponsor must acknowledge that the goods only remain exempt so long as:
- appropriate advice has been received from a Human Research Ethics Committee
- the trial is conducted in accordance with the:
- ICH Guideline for Good Clinical Practice (GCP) with TGA annotations
- National Statement on Ethical Conduct in Human Research (published by the National Health and Medical Research Council).
Can I start the trial once I have submitted the CTN form?
As soon as the requirements set out under Item 3 of Schedule 5A of the Therapeutic Goods Regulations 1990 (the Regulations) and Item 2.3 of Schedule 4 of the Therapeutic Goods (Medical Devices) Regulations 2002 have been met (i.e. submission of the online CTN form with payment of the relevant fee to the TGA), the clinical trial is deemed to have been notified.
Once this occurs, the exemption under Section 18(1), 32CA(2) and 41HA of the Therapeutic Goods Act 1989 (the Act) comes into effect, and the sponsor can supply the goods.
I have submitted a CTN form. Will I get a TGA acknowledgement letter?
The TGA does not send acknowledgment letters by email as this information can be viewed and printed via your online portal and provide evidence that your clinical trial has been notified to the TGA.
Instructions on how to obtain these print-outs is available in the 'Printing' section of the Clinical Trial Notification (CTN) form: User guide. We advise clinical trial sponsors to obtain and save a print-out of the CTN form at each stage of the submission process.
How do I notify multiple generics on the CTN form?
When multiple generic products with the same active ingredient are used, trial sponsors do not need to enter each trade/brand name separately on the CTN. In addition, an existing CTN does not need to be varied if additional generic versions are used of already notified products.
Trial sponsors should include the following information in the 'Medicine Details' sub-form of the online CTN form:
Field Name | Information required |
---|---|
Trade/Product/Code Name* | Enter the active ingredient followed by the word 'generic' e.g. paracetamol - generic |
Type of container* | Enter each separate container type into the free-text field. You can also edit this field when varying an existing CTN e.g. bottle, blister pack |
A generic product is defined in the Therapeutic Goods Regulations 1990, as a medicine that, in comparison with a registered medicine:
- has the same quantitative composition of therapeutically active substances, being substances of similar quality to those used in the registered medicine or previously registered medicine; and
- has the same pharmaceutical form; and
- is bioequivalent; and
- has the same safety and efficacy properties
Submitting and printing a CTN
I have completed the CTN form but I do not know how to submit?
See the Submitting section of the Clinical Trial Notification (CTN) form: User guide, for further assistance.
How do I obtain a print out of my CTN submission from the online portal?
See the Printing section of the Clinical Trial Notification (CTN) form: User guide, for further assistance.
You will need to allow pop-ups and clear your browser cache.
I get a blank screen or the screen returns to the online portal menu when I try to print my submission; what do I do?
- Please try clearing your browser cache and allowing pop ups on your internet browser.
- If you need assistance, please email clinical.trials@health.gov.au.
What do I do if I get an error message when I try to print my CTN submission?
If you receive an error message please email clinical.trials@health.gov.au and provide:
- A screen shot of the error message
- Your CTN application ID
- A short description of any steps you have taken to try and resolve the problem.
Fees, invoices and payments
What are the TGA costs related to clinical trials?
The current fees for clinical trials can be found in the TGA Schedule of fees and charges.
A fee is charged for a CTN submitted by a different sponsor as a result of transfer of sponsor responsibility.
A higher fee is applicable to applications for clinical trials under the CTA scheme due to the more complex nature of the evaluation process.
It is important to appreciate that the TGA cannot treat subgroups of trialists differently according to their ability to pay.
What generates a fee for a CTN
A fee is charged for the following:
- a new CTN
- a CTN submitted under a different sponsor entity
- certain variations to an existing CTN. The following variations to a previously notified trial will incur a fee:
- addition of new site(s) to a previously notified trial.
- change to previously notified therapeutic goods that creates separate and distinct goods
- addition of a new therapeutic good to a previously notified trial.
The applicable fee is the same amount as the fee for a new CTN in the current financial year.
I have submitted a variation to a previously notified trial. Will this variation incur a fee?
Certain variations to existing CTNs may incur a fee. The applicable fee is that of a new CTN as published in the schedule of fees and charges.
The following variations to a previously notified trial will incur a fee:
- addition of a new site(s) to a previously notified trial
- change to previously notified therapeutic goods that creates separate and distinct goods
- addition of a new therapeutic good to a previously notified trial.
If you submit a CTN variation that incurs a fee, an invoice will be sent via email to the submitter of the CTN and to the billing contact of your organisation as provided to TGA Business Services. Please submit the relevant payment to TGA Accounts Receivable as per the information on the TGA payment options web page. Credit card or account details should not be sent to the clinical trials team.
How can I make payments for a CTN?
Once you have submitted your CTN an invoice will be sent via email to the submitter of the CTN and to the billing contact of your organisation as provided to TGA Business Services. If you have a 'financial role' you will also be able to view and print the invoice in the online portal.
We recommend that you wait for the invoice before making payment as this ensures that there are no delays in matching payment.
Payment may be submitted through a range of options as described in our Payment options web page.
Payment through the online payment portal is the preferred option. To make a payment of an invoice:
- Select 'Biller code 1 - Payment of Invoice' from the drop down menu
- Enter your Client Identification Number (as shown on your invoice)
- Enter your Invoice Number(as shown on your invoice)
- Enter an email address for Tax receipt
- Enter the amount to be paid (this should correspond to the amount on your invoice)
- Select your payment option and follow the online prompts
Import, export and labelling
Do I need a permit to import clinical trial material?
Therapeutic goods may be imported and held under the direct control of the sponsor until the goods are included in a notification made to us through the CTN scheme. The goods must be kept in a warehouse or other properly secured area. The term 'sponsor' in these circumstances refers to the sponsor of therapeutic goods (the importer) as opposed to the sponsor of the clinical trial.
In other words, the importer does not require approval from the TGA prior to importation of the clinical trial goods; however the trial must be notified to the TGA through the CTN scheme prior to supply of the goods to the trial sites.
Sponsors are advised to contact other relevant agencies as there may be further restrictions on importation imposed through other legislation such as the Customs (Prohibited Imports) Regulation 1956, the Biosecurity Act 2015 and the Environment Protection and Biodiversity Conservation Act 1999.
What are the requirements for exporting therapeutic goods for use in clinical trials overseas?
You will need to apply for the TGA approval to export therapeutic goods overseas for use in clinical trials. Application forms and guidance are available on the Application forms and guidance are available on the Import/export of unapproved therapeutic goods for experimental purposes page of our website.
What are labelling requirements for investigational medicinal products (IMP) in clinical trials?
The TGA has adopted the PIC/S Guide for Good Manufacturing Practice for Medicinal Products, with Annex 13 of this guide referring to the manufacture of investigational medicinal products. Labelling requirements are outlined under items 26-33.
Six monthly supply reports
We do not require Australian clinical trial product importers/manufacturers to provide six monthly reports under regulation 47B of the Therapeutic Goods Regulations 1990. We understand that there are difficulties in determining the exact numbers supplied to health practitioners due to factors such as blinding and shipping of clinical trial supplies on a per site basis.
It is important to note that we can, from time to time, require information or documents relating to the supply (including quantity) of therapeutic goods that are exempt under the CTN scheme or approved under the CTA scheme, under sections 31A, 31B, 32JE, 32JG, 41JD, and 41JE of the Therapeutic Goods Act 1989.
Clinical trials involving medicinal cannabis products
Are there special requirements for medicinal cannabis products supplied in clinical trials?
Are there special requirements for medicinal cannabis products supplied in clinical trials
Sponsors of medicinal cannabis products imported into and supplied/manufactured in Australia must ensure that their products comply with all applicable quality standards. There are various standards that may apply to medicinal cannabis products, including the Therapeutic Goods (Standard for Medicinal Cannabis) (TGO 93) Order 2017.
Sponsors are no longer required to submit a 'Declaration of conformity with Therapeutic Goods Order (TGO) 93' form to the TGA. However, medicinal cannabis product sponsors continue to be legally responsible for ensuring that their products comply with the TGO 93, and all other relevant orders. Any breach is subject to a range of regulatory compliance actions, including civil and criminal penalties.
Review our Conforming with the TGO93 and Medicinal cannabis: Information for sponsors and manufacturers webpages for more information.
Other requirements
The therapeutic goods legislation requires that the use of therapeutic goods in a clinical trial conducted under the CTN/CTA schemes must be in accordance with:
- ICH Guidelines for Good Clinical Practice (GCP)
- National Statement on Ethical Conduct in Human Research (National Statement)
- The procedural protocol as approved by the Human Research Ethics Committee (HREC) responsible for monitoring the conduct of the trial.
Medical devices clinical trials
All trials investigating medical devices, regardless of device classification, should have an Investigator’s Brochure (IB), or equivalent documentation. Read more information at Investigator’s brochures for medical device clinical trials.
Contact us
If your enquiry is not specifically about clinical trials, see: Contact the TGA
Email: clinical.trials@health.gov.au
Phone: 1800 020 653 (freecall within Australia) or +61 2 6289 4124
Users who are deaf or have a hearing or speech impairment can call through the National Relay Service:
- TTY or computer with modem users: phone 1800 555 677 then ask for 1800 020 653
- Speak and listen (speech to speech relay) users: phone 1800 555 727 then ask for 1800 020 653