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India CDSCO: Adding Trial Sites and Changing Principal Investigators

Writer's picture: Sharan MuruganSharan Murugan

Clinical trials are a cornerstone of medical advancement, requiring meticulous planning and adherence to regulatory guidelines. In India, the Central Drugs Standard Control Organization (CDSCO) oversees the approval and conduct of clinical trials.


The Central Drugs Standard Control Organisation (CDSCO) has introduced new updates to the SUGAM portal, allowing online submissions for clinical trial site additions and principal investigator (PI) changes in biological product studies, including vaccines and recombinant DNA-based medicines. Researchers and sponsors often encounter two common scenarios: adding new clinical trial sites and changing the Principal Investigator (PI) during the trial. Both require formal submissions to the CDSCO.


The SUGAM portal is an online regulatory platform managed by CDSCO, designed to facilitate the submission and processing of applications related to:

  • Clinical trials

  • Marketing authorizations

  • Import and export licenses

  • Post-approval variations


Adding a New Clinical Trial Site

Expanding a clinical trial to include additional sites can accelerate recruitment and broaden the study's reach. However, each new site must be approved by the CDSCO before it begins participating in the trial. The submission process generally involves:

  • Justification: A clear rationale for adding the new site, including how it will contribute to the trial's objectives.

  • Site Details: Comprehensive information about the new site, including its infrastructure, facilities, and ethical committee.

  • Investigator Information: Details about the qualifications and experience of the investigators at the new site.

  • Ethics Committee Approval: Documentation of approval from the ethics committee at the new site.

  • Updated Trial Documents: Revised trial protocols, investigator brochures, and other relevant documents reflecting the addition of the new site.


Ensuring all documents are complete and accurate is crucial to avoid delays in the approval process. Sponsors should be prepared to answer any queries the CDSCO raises regarding the suitability of the new site.


Changing the Principal Investigator

The Principal Investigator (PI) plays a crucial role in the conduct of a clinical trial at a specific site. If a PI needs to be replaced, it's essential to follow the CDSCO's guidelines to ensure a smooth transition and maintain the integrity of the trial. Typically, the submission for a PI change includes:

  • Reason for Change: A clear explanation for the change in PI.

  • New PI's Credentials: Detailed information about the qualifications, experience, and training of the proposed new PI, demonstrating their suitability to lead the trial at the site.

  • Statement of Responsibility: A signed statement from the new PI accepting responsibility for the conduct of the trial at the site, adhering to the protocol and ethical guidelines.

  • Ethics Committee Approval: Approval from the ethics committee for the change in PI.

  • Updated Delegation Log: A log showing the delegation of tasks to the new PI.


The CDSCO will carefully review the qualifications of the proposed new PI to ensure they have the necessary expertise to oversee the trial effectively. A gap in PI coverage can significantly impact the trial's progress, so prompt and thorough communication with the CDSCO is vital.


Key Considerations for Both Submissions

  • Timeliness: Submit applications for site additions and PI changes well in advance of the planned implementation date.

  • Compliance: Ensure all submissions are in accordance with the latest CDSCO guidelines and regulations.

  • Communication: Maintain open communication with the CDSCO throughout the submission process.

  • Documentation: Keep meticulous records of all submissions, approvals, and communications.


These updates will enable faster study expansions and efficient investigator transitions, ultimately benefiting drug development and public health initiatives.

📌 For official CDSCO guidance, refer to the complete notice:🔗 CDSCO Official Notice

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