Research AppraisalSystematic Review

The use of complex clinical trials: a regulatory review.

TrialsNguyen, Quynh, Kästel, Hue, Hees, Katharina et al.9 Apr 2026DOI

Clinical Snapshot

40CEBM
Evidence: WeakSystematic Review

PICO Framework

P — PopulationComplex clinical trials submitted for scientific advice to regulatory agencies
I — InterventionComplex trial designs (adaptive designs, multiple arms, common controls)
C — ComparatorTraditional single-arm clinical trial designs and regulatory expectations
O — OutcomesRegulatory acceptance, feedback patterns, methodological concerns, and guidance adherence

Bottom Line

This systematic review of 30 German regulatory scientific advice procedures reveals that complex clinical trial designs are increasingly proposed and generally acceptable to regulators when appropriately designed. Key regulatory concerns mirror those in traditional trials but require enhanced attention to multiplicity control, pre-planned treatment arms, and appropriate control group definition. The review suggests that lack of multiplicity control may be acceptable in exploratory trials with independent cohorts, and common control groups are frequently proposed. However, the evidence base is limited by its single-agency focus and descriptive nature. For Australian clinical trialists, the findings emphasise the importance of early TGA engagement when planning complex adaptive designs, though specific Australian regulatory preferences may differ from European approaches.

Evidence: Weak

Key Findings

  • Effect Size: Not quantified - descriptive review

  • Primary Outcome: Regulatory acceptance patterns for complex clinical trial designs

  • Nnt Or Sensitivity: 30 scientific advice procedures from 29 complex trials reviewed

  • Confidence Interval: Not provided

Clinical Application

Moderate - requires early regulatory engagement and careful trial design planning Limited direct applicability - TGA guidance may differ from European approaches, though principles of early regulatory engagement remain relevant for Australian clinical trial sponsors Clinical researchers and pharmaceutical companies designing complex clinical trials

Abstract

BACKGROUND: Complex clinical trials offer flexibility in evaluating multiple treatments or diseases simultaneously. These trials often feature adaptive designs, common controls, and the potential to add new arms. However, the increased complexity raises methodological challenges particularly regarding multiple testing or the adequate choice of control groups. Despite guidance from regulatory bodies like the European Medicines Agency and the U.S. Food and Drug Administration, uncertainties remain about the regulatory acceptance of these trials. METHODS: This systematic review examines scientific advice procedures of products in the remit of the Paul-Ehrlich-Institut for complex clinical trials to highlight key concerns and regulatory feedback. We identified 30 scientific advice procedures corresponding to 29 different complex clinical trials. RESULTS: Our findings reveal an increasing number of complex trial designs proposed by applicants. A lack of multiplicity control due to multiple arms was generally considered acceptable by regulators in exploratory trials and if cohorts can be considered independent. Additionally, the use of common control groups is frequently proposed by applicants. The review underscores the importance of pre-planning for new treatment arms, appropriate multiplicity control, and the definition of control groups in trial designs. CONCLUSION: Overall, our findings suggest that regulatory concerns regarding complex trials largely align with those in traditional trial designs, though their complexity requires careful, case-by-case consideration. Early engagement with regulatory agencies can be crucial to ensure the successful design and implementation of these trials.

References

  1. 1.Nguyen, Q., Kästel, H., Hees, K., & Hofner, B. (2026). The use of complex clinical trials: a regulatory review. Trials. https://doi.org/10.1056/nejmra1510062
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