Pharmacovigilance requirements: qualified person for PV and PSMF
Source: gov.uk (2025-01-08)

Guide for marketing authorisation holders, including qualified person responsible for pharmacovigilance (PV) and pharmacovigilance system master files (PSMF).

1. Overview

The following legal obligations apply to holders of UK marketing authorisations (MA). These include products authorised as both Category 1 and Category 2 and those authorised as a PLNI or a PLGB licence:
- to operate a pharmacovigilance system for UK authorised products
- to have an appropriately qualified person responsible for pharmacovigilance (QPPV) who resides and operates anywhere in the UK or in the EU/EEA and is responsible for the establishment and maintenance of the pharmacovigilance system for UK authorised products
- to maintain and make available upon request a pharmacovigilance system master file (PSMF) that describes the pharmacovigilance system for UK authorised products - the PSMF must be accessible electronically from the UK at the same site at which reports of suspected adverse reactions may be accessed
2. Guidance on the QPPV for UK authorised products

For all UK MAs, the marketing authorisation holder (MAH) must have permanently and continuously at its disposal a qualified person responsible for pharmacovigilance (QPPV) who resides and operates anywhere in the UK or in the EU/EEA, and is responsible for the establishment and maintenance of the pharmacovigilance system (“the UK QPPV”). Where the QPPV is not in the UK, there will be a need for a national contact person for pharmacovigilance as set out below.

This is provided for by regulation 182 of the Human Medicines Regulations 2012 (HMR).

For Category 2 MAs, the legal requirements concerning the qualifications and responsibilities of the QPPV that are outlined in Article 10 of the Commission Implementing Regulation (EU) No 520/2012 (IR) will remain unchanged.

For Category 1 MAs or any PLGBs granted by the MHRA, legal requirements concerning the qualifications and responsibilities of the QPPV are outlined in paragraph 10 of HMR Schedule 12A (inserted by the EU Exit Regulations 2019), which mirrors Article 10 of CIR.

Statutory guidance concerning the QPPV for UK authorised products is described in the Good Pharmacovigilance Practices (GVP) Module I. This guidance is supplemented by the Exceptions and modifications to the EU guidance on good pharmacovigilance practices that apply to UK marketing authorisation holders (https://www.gov.uk/government/publications/exceptions-and-modifications-to-the-eu-guidance-on-good-pharmacovigilance-practices-that-will-apply-to-uk-mahs-and-the-mhra).

There is no temporary exemption as to the requirement to have a QPPV who resides and operates in the UK or the EU/EEA and is responsible for the pharmacovigilance system for UK authorised products.

2.1 National contact person for pharmacovigilance

If you choose to establish a QPPV who resides and operates in the EU/EEA, you must nominate a national contact person for pharmacovigilance who resides and operates in the UK and reports to the QPPV. This individual should have access to the reports of suspected adverse reactions referred to in regulation 187 of the HMRs and the PSMF for UK authorised products. The individual should be able to facilitate responses to pharmacovigilance queries raised by the MHRA, including via inspections.

Once the national contact person for pharmacovigilance has been appointed, their details should be notified to the MHRA via the MHRA Submissions Portal (https://mhrabpm.appiancloud.com/suite/). You should follow the instructions for submitting these details. You should receive a confirmation by email immediately upon completion of the form.

There is no requirement to appoint a deputy for the UK national contact person for pharmacovigilance, but for periods of extended absence greater than one month (such as maternity leave, long-term sick leave), you should assign another individual as the national contact person for pharmacovigilance and notify their details to the MHRA within 2 weeks of the change. In practice, this means editing the existing details of the national contact person for pharmacovigilance that are saved in the MHRA Submissions portal.

3. Guidance on the PSMF for UK authorised products

For all UK MAs, the MAH must maintain, and make available upon request of the MHRA, a PSMF that describes the pharmacovigilance system for UK authorised products (“the UK PSMF”).

3.1 PSMF accessibility in the UK

All UK PSMFs must be accessible electronically at the same point in the UK from which the reports of suspected adverse reactions referred to in regulation 187 of the HMRs are accessible.

The PSMF needs to be permanently and immediately available for inspection at the stated location in the UK. The content in the PSMF must be up to date at the point it is requested by the MHRA.

3.2 PSMF format, content and representation of pharmacovigilance systems

For Category 2 MAs or PLNIs, the legal requirements concerning the format and content of the PSMF that are outlined in Chapter I of IR will remain unchanged.

For Category 1 MAs or those which the MHRA grant as PLGBs , legal requirements concerning the format and content of the PSMF are outlined in Part 1 of Schedule 12A of HMR, which mirrors Chapter I of IR.

As the legal requirements concerning PSMF format and content are identical for all UK MAs, a single UK PSMF can be used for all UK authorised products. This is assuming that the pharmacovigilance system applied to all products is the same.

Statutory guidance concerning the PSMF for UK authorised products is described in GVP Module II. This guidance is supplemented by the Exceptions and modifications to the EU guidance on good pharmacovigilance practices that apply to UK marketing authorisation holders (https://www.gov.uk/government/publications/exceptions-and-modifications-to-the-eu-guidance-on-good-pharmacovigilance-practices-that-will-apply-to-uk-mahs-and-the-mhra).

The UK PSMFs must describe the global pharmacovigilance system and reflect the global availability of safety information for UK authorised products.

As per GVP Module II, there are different approaches to establishing a pharmacovigilance system. For example:
- MAHs can establish more than one pharmacovigilance system
- several MAHs can share a pharmacovigilance system
The UK PSMF should be an accurate representation of the pharmacovigilance system that has been established and you must make sure that every pharmacovigilance system covering UK authorised products has been assigned a unique PSMF number by the MHRA.

3.3 How to request a UK PSMF number

All PSMFs that cover UK authorised products should be registered with the MHRA. You should request a unique UK PSMF number from the MHRA for each pharmacovigilance system that you are operating for UK authorised products. Where the pharmacovigilance system is shared by several MAHs, a single request for a UK PSMF number should be submitted to the MHRA. You can request a UK PSMF number through the MHRA Submissions Portal (https://mhrabpm.appiancloud.com/suite/). You should follow the online instructions for requesting a UK PSMF number and you should receive the number by email immediately upon completion of the form. The address from which the PSMF can be electronically accessed must be in the UK. Your UK PSMF number will be invalidated if the address provided is not in the UK. Any submissions to the MHRA using an invalidated UK PSMF number will not be accepted.

The UK PSMF number will be sent to the UK QPPV email address as well as the email address you nominated on the UK PSMF number request form. If you have not received a confirmation email within 3 hours of submitting the form, contact xxx@xxx.xx (mailto:xxx@xxx.xx). Do not re-submit the form as this will cause delays in processing your request.

Once a UK PSMF number is assigned to a pharmacovigilance system it should remain unchanged, irrespective of how the system may change and evolve over time. You should not request a new UK PSMF number if there are changes to the pharmacovigilance system, including a change of UK QPPV.

You do not need to update the initial information that was provided in the online form at the time of requesting your UK PSMF number (for example, QPPV telephone number, MAHs covered by the pharmacovigilance system). This information is solely for the purpose of generating and allocating a unique UK PSMF number at a specific point in time. You must maintain the pharmacovigilance system information for your UK licences via the submission of the appropriate variations to the MHRA. Guidance on notifying details to the MHRA is available below (#notification-of-qppv-and-psmf-details-to-the-mhra-by-existing-holders-of-uk-marketing-authorisations).

4. Guidance for applicants for UK marketing authorisations

The material to accompany an application for a UK marketing authorisation includes a summary of the applicant’s pharmacovigilance system (SPS).

This must include the following elements:
- proof that the applicant has at their disposal an appropriately qualified person responsible for pharmacovigilance who resides and operates in the EU/EEA or the UK
- the country (which must be either the UK or a EU/EEA country) where the appropriately qualified person resides and carries out his or her tasks
- the contact details of the appropriately qualified person
- a statement signed by the applicant which says that they have the necessary means to fulfil the tasks and responsibilities listed in Part 11
- a reference to the location where the pharmacovigilance system master file for the medicinal product can be accessed electronically, which must be in the UK
The SPS should also include the UK PSMF number.

The above is following HMR Schedule 8.

Guidance on the application process and on registering to make submissions via the MHRA Submissions Portal (https://www.gov.uk/guidance/mhra-portal-register-to-submit-forms) is available.

You should use Agency Activity Reference ID: G0001 – Initial Marketing Authorisation Application and Subactivity Text: H002 – “Original Submission”.

Information on the QPPV and PSMF for UK authorised products should be entered in section 2.4.4 of the electronic application form (eAF). You should note the following:
- if the QPPV for UK authorised products resides and operates in the UK, the checkbox entitled “The above-mentioned qualified person resides and operates in the EEA” can remain unchecked
- the UK location where the PSMF can be accessed from does not need to be registered in the Article 57 database, therefore the associated checkbox can remain unchecked
- for UK licence applications via mutual recognition or decentralised procedures, the UK SPS should be included in module 1.8.1 as a standalone file or alternatively under a UK subfolder
5. Notification of QPPV and PSMF details to the MHRA by existing holders of UK marketing authorisations

This guidance replaces the previous requirement to submit a Type IA(IN) variation and an accompanying eCTD sequence following updates to the UK PSMF and UK QPPV information. New procedures have been designed to simplify processes to notify the MHRA of these types of changes. This guidance applies from 11 May 2023.

The following changes to the SPS will no longer require the submission of a Type IA variation to update the SPS but can be submitted via an update notification of:
- the UK QPPV details (UK QPPV name, address and contact details)
- the location in the UK where the UK PSMF can be electronically accessed
To make these changes, a UK-only SPS update notification, covering the affected product licences (PL) under a unique pharmacovigilance system, must be submitted to the UK to register these changes. There is currently no fee for SPS update notifications. A notification of acceptance letter will be issued once finalised on our systems. SPS update notifications will be processed within 30 days of receipt of the notice.

5.1 How to make an SPS update notification

All notifications to update the SPS must be submitted as an SPS update notification through the MHRA Submissions Portal immediately following implementation. This should be submitted within 14 days. The notification should be made in the following links in the portal:
- Agency Activity Reference ID G0109: Summary of Pharmacovigilance System Update Notification - UK-QPPV-PSMF
- Subactivity Text: H002 – “Original Submission” must be selected
You must submit your SPS update notifications outside of the eCTD product lifecycle, in collections of no more than 25 PLs and you should submit no more than one collection in a single package.

5.2 Documentation you need to supply:

You must supply the following documentation for an SPS update notification:
- cover letter (in PDF format) detailing the changes being made
- SPS-update-notification-form (in Excel format) - download a copy of the notification form (https://assets.publishing.service.gov.uk/media/65562c61046ed4000d8b9a51/sPS-Update-Notification-form.xlsx) and complete sections A, B and C
The SPS (in PDF format) should be a single document and must include the following elements.
- proof that the applicant has at their disposal an appropriately qualified person responsible for pharmacovigilance who resides and operates in the EU or the UK
- the country (which must be either the UK or a member state) in which the appropriately qualified person resides and carries out his or her tasks
- the contact details of the appropriately qualified person
- a statement signed by the applicant which says that they have the necessary means to fulfil the tasks and responsibilities listed in Part 11 of the Human Medicines Regulation 2012 as amended
- a reference to the location where the pharmacovigilance system master file for the medicinal product can be accessed electronically, which must be in the UK
The SPS should also include the UK PSMF number.

Failing to supply all required documentation and information may lead to a rejection of the SPS changes, which will require you to make a resubmission addressing all discrepancies.

A notification of acceptance letter will be issued when we have made the changes on our system.

Please note that any eCTD sequence submitted will be discarded as it is not required as part of this process.

5.3 Changes to the UK PSMF number

You can submit changes to the UK PSMF (and associated information) for product licences (PLs) made due to change of ownership:
- as part of the change of ownership (COA) dossier
- or following grant of the COA application (whether this has resulted in a change to the UK PSMF number or not)
- If you wish to submit the changes to the UK PSMF number for a PL as part of a COA application, a copy of the updated SPS may be included under module 1.8.1 of the COA dossier. This update should also include information regarding changes to the UK QPPV details and UK location of the UK PSMF. Any subsequent changes to the UK PSMF number or other details of the SPS following grant of the COA should be notified to the MHRA as per the guidance on this website.
- If you wish to submit the changes to the UK PSMF number (and associated information) after grant of the COA and not as part of the COA dossier, a Type IA(IN) variation should be submitted within 14 days after the change of ownership has been granted.
Changes to the UK PSMF number (and associated information) for product licenses (PLs) made for any other reason, must still be submitted via a Type IA(IN) variation within 14 days of the change taking effect.

6. Notification of QPPV and PSMF details to XEVMPD

From 1 January 2021, for Category 2 products and PLNIs, in addition to notifying the QPPV and PSMF details to the MHRA, you must submit information on the UK QPPV and the EU location of the UK PSMF to the Article 57 database in accordance with Regulation (EC) No 726/2004 Article 57(2).

6.1 Webinar recordings

The following webinar recordings on pharmacovigilance requirements for UK authorised products webinars are available:

This webinar was part of a series of Brexit and post-transition guidance webinars and took place on 13 January 2020:

Pharmacovigilance requirements for UK authorised products webinar recording, which took place on 13 January 2020: (https://youtu.be/AGTitnGny50)

Post transition: Pharmacovigilance requirements for UK authorised products webinar recording, which took place on 22 October 2020:

Pharmacovigilance requirements for UK authorised products webinar recording, which took place on 22 October 2020. (https://youtu.be/I3CkPHWQI8M)

Windsor Framework webinar which took place on 19 September 2024:

Windsor Framework webinar, 19 September 2024 (https://www.youtube.com/watch?v=q4Mp2H3PzZs)

7. Contact

For general queries relating to the QPPV, PSMF and establishment of pharmacovigilance systems for UK authorised products, contact xxx@xxx.xx (mailto:xxx@xxx.xx).

For queries relating to the UK PSMF number, contact xxx@xxx.xx (mailto:xxx@xxx.xx).

For queries relating to submission of Type IA variations, contact xxx@xxx.xx (mailto:xxx@xxx.xx).

For further information, contact our Customer Services Centre at xxx@xxx.xx (mailto:xxx@xxx.xx) or call xx-xxxx-xxxx. You can also email xxx@xxx.xx (mailto:xxx@xxx.xx) with urgent questions. Alternatively, contact your trade association.