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Revised EU- PIC/S GMP on Documentation, Computer Systems and AI

Date
July 21, 2025
Category

EU Regulations

Description

On 7 July 2025 the EU and PIC/S jointly published draft revisions to the following sections of their GMP guides:

  • Chapter 4, Documentation
  • Annex 11, Computer Systems
  • Annex 22, a new annex on Artificial Intelligence.

See Stakeholders’ Consultation on EudraLex Volume 4 - Good Manufacturing Practice Guidelines: Chapter 4, Annex 11 and New Annex 22 - European Commission

Comments on these proposed changes should be submitted by 7 October 2025.

The changes are being proposed in light of the rapid advancement of digital technologies and the implementation of AI systems in pharmaceutical manufacturing, to ensure that the GMP guidelines continue to provide clear, practical and relevant guidance for manufacturers and national competent authorities. The specific changes to the three sections of the GMP Guide are as follows:

Chapter 4 – Documentation

The chapter has been restructured and significantly expanded. The revised chapter has a focus on data integrity throughout and the new structure is as follows:

  • Principle
  • Data governance systems
  • Risk management
  • General requirements for documentation
  • Master Documents
  • Generation and Control of Documentation
  • Good documentation practice
  • Signatures in GMP relevant documentation
  • Retention of documents
  • Data Integrity in documentation
  • Hybrid Systems
  • Glossary.

Annex 11 – Computer Systems

This annex has also been restructured and significantly expanded, going from 5 pages to 19. The new structure has the following subject headings:

  1. Scope
  2. Principles
  3. Pharmaceutical Quality System
  4. Risk Management
  5. Personnel and Training
  6. System Requirements
  7. Supplier and Service Management
  8. Alarms
  9. Qualification and Validation
  10. Handling of Data
  11. Identity and Access Management
  12. Audit Trails
  13. Electronic Signatures
  14. Periodic Review
  15. Security
  16. Backup
  17. Archiving.