Human Research Act (HRA) and Clinical Trials in Switzerland
Short answer
Clinical trials with medicinal products in Switzerland need two authorisations: the competent ethics committee and, depending on the category, Swissmedic. The legal basis is the Human Research Act and the Clinical Trials Ordinance. Applications are filed via the BASEC portal, coordinated with the Swissmedic Portal.
Who authorises a clinical trial?
Always the competent cantonal ethics committee. Additionally Swissmedic, where the trial involves a medicinal product, a medical device or a transplant and falls into a category requiring regulatory authorisation. Both procedures run in parallel and are coordinated.
| Category | Feature | Swissmedic authorisation |
|---|---|---|
| Category A | Authorised medicinal product in its authorised use | no, notification suffices |
| Category B | Authorised medicinal product, use outside its authorisation | yes |
| Category C | Unauthorised medicinal product or gene therapy | yes, with extended review |
The classification determines the effort and the timelines. It follows the additional risk the investigational intervention creates compared with standard treatment.
How does the submission process work?
The application to the ethics committee is submitted via BASEC, the Swissmedic application via the Swissmedic Portal. The authorities coordinate with each other. The ethics committee generally decides within 30 days of a complete application, Swissmedic within a comparable timeframe.
- Determine the category and identify the competent ethics committee.
- Prepare the trial protocol, investigator's brochure, information and consent documents, and insurance evidence.
- Submit the application via BASEC, and in parallel to Swissmedic for category B or C.
- Answer formal review questions and adjust documents.
- Wait for the authorisations, then register the trial in a recognised registry.
- Report the trial start and comply with safety reporting and annual reports.
- Report the end of the trial and the final report.
What duties does the sponsor have during the trial?
It reports serious adverse events within the set deadlines, informs about safety measures, submits annual reports, seeks authorisation for substantial protocol amendments before implementing them, and ensures the trial is conducted under Good Clinical Practice.
- Suspected serious unexpected adverse drug reactions: reported within the deadlines of the Clinical Trials Ordinance.
- Safety and protective measures: immediate report to the ethics committee and Swissmedic.
- Substantial amendments: authorisation before implementation.
- Annual safety report on the trial's course.
- Registration in a primary registry recognised by Switzerland.
- Retention of trial documents for the statutory periods.
What role does swissethics play?
swissethics is the association of the cantonal ethics committees. It harmonises templates, publishes model documents for information and consent, and operates the BASEC portal together with the committees. Authorisation, however, is always granted by the individual competent committee.
Frequently asked questions
Do I need authorisation for an observational study?
For research projects involving personal data or biological material, ethics committee authorisation is generally needed. A Swissmedic authorisation is not required where there is no investigational intervention with a therapeutic product.
How long does authorisation take?
The ethics committee generally decides within 30 days of a complete application, Swissmedic within a comparable timeframe. Queries extend the procedure.
What is BASEC?
The joint electronic submission portal of the Swiss ethics committees for research projects involving human subjects.
Do I need trial insurance?
Yes. Human research law requires that damage arising from the trial be covered, generally through subject insurance with the prescribed coverage amounts.
Who may manufacture investigational medicinal products?
Operations with a manufacturing licence covering medicinal products for clinical trials. Importing investigational medicinal products requires an import licence.
Sources
- Fedlex SR 810.30 Human Research Act (HRA)
- Fedlex SR 810.305 Clinical Trials Ordinance (KlinV)
- swissethics
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