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Pharmacovigilance Requirements in India

Pharmacovigilance Guidance Document for Marketing Authorization Holders of Pharmaceutical Products (Version: 2.0)

In India, Pharmacovigilance is governed by a dual framework: the New Drugs and Clinical Trial (NDCT) Rules, 2019 for clinical trials and the Pharmacovigilance Programme of India (PvPI) for post-marketing surveillance.

1. Clinical Safety (During Clinical Trials)

Requirements under the NDCT Rules, 2019 (which superseded Schedule Y) focus on trial participant safety:

  • SAE Reporting Timelines: Investigators must report any Serious Adverse Event (SAE) to the CDSCO, the Sponsor, and the Ethics Committee (EC) within 24 hours of occurrence.

  • Formal Reporting: The Sponsor must submit a detailed report on the SAE to the CDSCO within 14 days.

  • Medical Care & Compensation: Sponsors are legally mandated to provide free medical management and financial compensation for trial-related injuries or deaths. Compensation is calculated using specific formulas defined in the NDCT Rules.

  • Ethics Committee Oversight: Continuous monitoring by a registered EC is mandatory. The EC must review SAEs and provide recommendations on causality and compensation to the Central Licensing Authority.

  • Annual Status Reports: Sponsors must submit an annual report to the CDSCO summarizing the safety and progress of the trial.

2. Post-Marketing Pharmacovigilance

Once a drug is approved, the Pharmacovigilance Guidance Document for Marketing Authorization Holders (MAHs) (Version 2.0, 2024) dictates compliance:

  • Pharmacovigilance System Master File (PvMF): Every MAH must maintain a PvMF describing their Pharmacovigilance system. It must be located in India.

  • Pharmacovigilance Officer In-charge (PvOI): Companies must appoint a PvOI (Medical Officer or Pharmacist) based in India to oversee safety operations.

  • Periodic Safety Update Reports (PSURs):

    • For the first two years after approval: Submit every 6 months.

    • For the subsequent two years: Submit annually.

    • Submission must be made via the SUGAM portal within 30 days of the data lock point.

  • Expedited Reporting: All serious unexpected adverse reactions must be reported to the National Coordination Centre (NCC-PvPI) within 15 days.

  • Risk Management Plan (RMP): Required for new drugs to outline how safety risks will be monitored and mitigated in the real-world population.

Summary of Key Bodies

Entity Role
CDSCO The central regulatory authority that enforces the Drugs and Cosmetics Act/Rules.
NCC-PvPI Located at the Indian Pharmacopoeia Commission (IPC); serves as the national hub for ADR data collection.
ADR Monitoring Centres (AMCs) Over 250 centers (mostly medical colleges) that collect and forward safety data to the NCC.

Human Vaccines’ Safety Guidelines in India Version 2. 

Toll-Free Number for Reporting

Helpline Number Managed by NCC PvPI to provide assistance in ADRs reporting for the HCPs and general public:

1800 180 3024 (All Working Days 9:00 AM to 5:30 PM IST)

Adverse Event reporting form for patients in Hindi & other Vernacular Languages
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