INOPP Forum
Pharmacovigilance Requirements in Germany
Quote from VigiServe Admin on March 15, 2026, 11:44 AMIn Germany, the pharmacovigilance system is fully integrated into the European Union framework and enforced by the Bundesinstitut für Arzneimittel und Medizinprodukte (BfArM) and the Paul-Ehrlich-Institut (PEI). All EU pharmacovigilance legislation, including Good Pharmacovigilance Practices, applies directly through the Medicinal Products Act (AMG).
1. Clinical Safety (Clinical Trials)
Clinical trials are governed by the EU Clinical Trials Regulation (CTR 536/2014) and require approval via the Clinical Trials Information System (CTIS).
Expedited Reporting: Sponsors must report Suspected Unexpected Serious Adverse Reactions (SUSARs) to EudraVigilance.
Fatal or Life-Threatening: Within 7 calendar days.
Other Serious Unexpected: Within 15 calendar days.
Periodic Reporting: Development Safety Update Reports (DSURs) are required annually.
Submission: Electronic submission via CTIS and EudraVigilance.
2. Post-Marketing Pharmacovigilance
Marketing Authorization Holders must maintain a pharmacovigilance system compliant with EU Good Pharmacovigilance Practices.
Personnel & Infrastructure:
Qualified Person for Pharmacovigilance: Mandatory. An EU-resident, qualified professional must be appointed and registered.
Pharmacovigilance System Master File: Mandatory. Must be available for inspections by BfArM or PEI.
Incident Reporting (ICSRs):
Timelines:
Serious: Within 15 calendar days.
Non-Serious: Within 90 calendar days.
Submission: All reports are submitted electronically to EudraVigilance.
Risk & Periodic Reporting:
Periodic Benefit-Risk Evaluation Reports: Mandatory. Frequency aligns with the EU EURD list (typically every six months initially, then annually).
Risk Management Plans: Mandatory for new active substances, biologics, and high-risk products.
Additional Monitoring: Medicines under intensive monitoring must display the black inverted triangle (▼) in the SmPC and package leaflet.
Summary of Requirements
Component Requirement in Germany Regulatory Authority BfArM / PEI Framework EU Good Pharmacovigilance Practices / AMG Local Qualified Person for Pharmacovigilance Yes (EU Qualified Person) Pharmacovigilance System Master File Yes Safety Reporting 15 days (Serious) / 90 days (Non-Serious) Clinical Reporting SUSARs (7/15 days - EU CTR) Submission Language German / English
In Germany, the pharmacovigilance system is fully integrated into the European Union framework and enforced by the Bundesinstitut für Arzneimittel und Medizinprodukte (BfArM) and the Paul-Ehrlich-Institut (PEI). All EU pharmacovigilance legislation, including Good Pharmacovigilance Practices, applies directly through the Medicinal Products Act (AMG).
1. Clinical Safety (Clinical Trials)
Clinical trials are governed by the EU Clinical Trials Regulation (CTR 536/2014) and require approval via the Clinical Trials Information System (CTIS).
-
Expedited Reporting: Sponsors must report Suspected Unexpected Serious Adverse Reactions (SUSARs) to EudraVigilance.
-
Fatal or Life-Threatening: Within 7 calendar days.
-
Other Serious Unexpected: Within 15 calendar days.
-
-
Periodic Reporting: Development Safety Update Reports (DSURs) are required annually.
-
Submission: Electronic submission via CTIS and EudraVigilance.
2. Post-Marketing Pharmacovigilance
Marketing Authorization Holders must maintain a pharmacovigilance system compliant with EU Good Pharmacovigilance Practices.
-
Personnel & Infrastructure:
-
Qualified Person for Pharmacovigilance: Mandatory. An EU-resident, qualified professional must be appointed and registered.
-
Pharmacovigilance System Master File: Mandatory. Must be available for inspections by BfArM or PEI.
-
-
Incident Reporting (ICSRs):
-
Timelines:
-
Serious: Within 15 calendar days.
-
Non-Serious: Within 90 calendar days.
-
-
Submission: All reports are submitted electronically to EudraVigilance.
-
-
Risk & Periodic Reporting:
-
Periodic Benefit-Risk Evaluation Reports: Mandatory. Frequency aligns with the EU EURD list (typically every six months initially, then annually).
-
Risk Management Plans: Mandatory for new active substances, biologics, and high-risk products.
-
Additional Monitoring: Medicines under intensive monitoring must display the black inverted triangle (▼) in the SmPC and package leaflet.
-
Summary of Requirements
| Component | Requirement in Germany |
| Regulatory Authority | BfArM / PEI |
| Framework | EU Good Pharmacovigilance Practices / AMG |
| Local Qualified Person for Pharmacovigilance | Yes (EU Qualified Person) |
| Pharmacovigilance System Master File | Yes |
| Safety Reporting | 15 days (Serious) / 90 days (Non-Serious) |
| Clinical Reporting | SUSARs (7/15 days - EU CTR) |
| Submission Language | German / English |