On April 16, 2019, Health Canada released a notice inviting drug submissions containing high quality real world evidence along with a document providing principles for the collection and evaluation of real world evidence.
Submissions containing real world evidence are encouraged in the following circumstances: to “expand evidence-based indications for populations often excluded from clinical trials”; “for drugs/diseases where clinical trials are unfeasible”; or “where clinical trials are unethical”. Sponsors must clearly identify that a submission contains real world evidence. When real world evidence is used as pivotal evidence, a sponsor must also (i) provide a rationale for its use; (ii) provide a detailed explanation of its collection/analysis; (iii) demonstrate how biases in data collection were mitigated; and (iv) contact Health Canada to determine whether a pre-submission meeting would be beneficial.
A further joint document regarding the use of real world evidence is in development by Health Canada, CADTH and INESSS with an anticipated release date of later this year.
Related Publications & Articles
-
Health Canada consultation on two draft guidance documents on terms and conditions for human and veterinary drugs and drug submissions based on promising evidence of clinical efficacy
As previously reported, in December 2024, Health Canada published its agile licensing amendments to the Food and Drug Regulations.Read More -
2025 highlights in Canadian life sciences IP and regulatory law
In 2025, the Rx IP Update team at Smart & Biggar reported on a number of developments in Canadian life sciences IP and regulatory law.Read More -
Proposed Ministerial Reliance Order would allow Health Canada to rely on decisions of foreign trusted regulators
On December 19, 2025, the Minister of Health announced the launch of consultations on two key regulatory initiatives referenced in Health Canada’s Red Tape Review report: (i) the Ministerial Reliance ...Read More
