Pharmaceutical Market Europe • September 2026 • 36-37

ADAPTING TO REGULATORY UNCERTAINTY

Regulatory complexity: the challenges of navigating the new normal

How functional service provider models are helping pharma adapt to regulatory uncertainty

By Myriam Antoun

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Logistical challenges are not new in clinical research, from the high cost of developing new therapies to complexities in trial enrolment and operations. Agility and flexibility have always been important to trial design, but they are now becoming essential in the face of rising regulatory complexity. This complexity is driven by shifting global policies and increasingly divergent regional requirements, alongside a steady flow of regulatory updates.

What was once a manageable operational consideration has become a significant strategic challenge for the industry. As a result, it is becoming increasingly difficult for drug developers to plan and execute clinical programmes with confidence.

The consequences are substantial, including missed development milestones, delayed regulatory submissions and downstream commercial impact. Even modest delays can carry significant financial burden, with a single day of delay in a clinical trial estimated to result in approximately $500,000 in unrealised prescription drug sales and $40,000 in direct daily costs.

Many organisations’ instinct in response to this complexity has been to absorb it internally: hiring additional staff; stretching existing teams and relying heavily on institutional knowledge to bridge the gaps. However, this approach is increasingly insufficient given the pace of regulatory change. The challenge is no longer simply about capacity; it is about accessing the most appropriate specialised expertise to interpret evolving requirements, assess their impact across development programmes and respond before timelines or outcomes are affected.

As the regulatory landscape continues to evolve, a growing number of drug developers are shifting their approach. Rather than building rigid structures against uncertainty, they are prioritising flexibility, with functional service provider (FSP) models playing a central role.

From compliance function to strategic capability

For decades, regulatory affairs has primarily been viewed as a compliance function, responsible for ensuring submissions meet regulatory requirements and organisations remain aligned with evolving guidance. That model is no longer sufficient in today’s environment.

Regulatory strategy has now become a core operational capability. Organisations must not only understand requirements but also anticipate change, assess its implications across development programmes and act early enough to avoid disruption. The ability to navigate regulatory complexity with speed and confidence is increasingly a competitive advantage.

Companies that do this well are better positioned to accelerate development timelines, reduce the need for late-stage remediation and avoid regulatory surprises that can delay approval or commercialisation. They are also able to make earlier, more informed decisions that improve overall programme efficiency.

FSP models are enabling this shift by embedding regulatory expertise directly within clinical development and operational teams. Rather than relying on intermittent support or overstretched internal groups, sponsors gain continuous access to specialists who monitor regulatory developments, interpret changes in context and translate them into actionable guidance.

This embedded approach allows organizations to identify risks earlier, adapt more quickly to evolving expectations and maintain momentum in increasingly complex development environments. As regulatory complexity grows, companies that treat regulatory affairs as a strategic capability, rather than a standalone function, are better positioned to bring therapies to patients faster.

The scale of the challenge

The challenge facing drug developers is not simply keeping pace with regulatory change, but understanding which changes matter and how they affect specific programmes across markets.

For global organisations, this requires continuous monitoring and interpretation of regulatory intelligence from multiple sources, including national and regional regulations, guidance updates, authority communications and industry outputs. Each of these can have implications for protocol design, submission strategy or operational execution.

Beyond monitoring, effective regulatory intelligence depends on interpretation. The impact of regulatory change varies depending on both the market and the stage of development, requiring contextual expertise that is difficult to maintain internally at scale.

Why the FSP model is well suited to this problem

The FSP model addresses regulatory complexity through a timely combination of scale, specialisation and integration that can be challenging to replicate within a single operating structure.

At the monitoring level, FSP partners maintain structured systems to track regulatory intelligence across markets. These systems capture not only headline changes but also procedural guidance, authority clarifications and regional nuances that often drive operational impact.

At the analysis level, locally based experts provide context-specific insight and, where needed, engage directly with regulatory authorities in local languages. This helps reduce misinterpretation and improves the speed and quality of decision-making.

The implementation of the EU Clinical Trials Regulation (CTR) and Clinical Trials Information System (CTIS) illustrates how regulatory change can create periods of intense operational demand. Sponsors were required to revise established submission processes, adapt operating models and develop new expertise within relatively short timelines. For organisations managing studies across multiple countries, resource requirements often increased rapidly during the transition period as teams worked to understand new requirements, update procedures and support ongoing studies.

Once the transition activities were completed and organisations became more familiar with the new framework, those resource needs did not necessarily remain at the same level. This highlights a broader challenge in regulatory affairs: major regulatory changes can generate periods of intense activity that are difficult to predict and inefficient to support through permanent headcount alone. FSP partnerships provide the flexibility to scale specialised regulatory expertise when needed and adjust support as requirements evolve, helping sponsors navigate periods of change without overextending internal teams.

Even after implementation, the EU CTR continues to evolve as regulators and stakeholders gain experience with the framework. Variations in interpretation and evolving guidance still create complexity for sponsors running multinational studies. Access to local expertise through FSP models helps organisations respond more effectively while maintaining compliance across jurisdictions.

At the operational level, regulatory intelligence is translated into concrete updates to procedures, systems and study designs before new requirements take effect. A key advantage of the FSP model in an evolving regulatory environment is its structural flexibility. When requirements shift, resources can be scaled or redeployed quickly across geographies and programmes, helping maintain continuity and responsiveness.

This is particularly valuable for biopharma and biotech organisations that may not have the internal infrastructure to build deep regulatory capability across all markets. FSP partnerships provide access to expertise and systems that would be difficult to replicate internally.

AI and the next generation of regulatory intelligence

The application of AI and advanced analytics is beginning to reshape how regulatory intelligence is gathered and processed. The volume of regulatory data that must be monitored globally now exceeds what can be managed through manual processes alone. AI-assisted tools are enabling faster identification of relevant changes and earlier detection of emerging trends, improving how regulatory signals are translated into operational guidance.

However, identifying a regulatory update is only the first step. While AI can support the monitoring of large volumes of regulatory information and surface potentially relevant changes, determining what those changes mean in practice still requires scientific and regulatory expertise. A new guidance document or regulatory clarification may appear straightforward, but assessing its impact on ongoing studies or submission strategies often requires careful interpretation. The value lies not only in recognising that a change has occurred, but in understanding its implications and deciding how and when to respond. Access to experienced regulatory professionals through an FSP model can help sponsors translate regulatory intelligence into practical actions, while maintaining flexibility as needs evolve.

FSP partners are well positioned to integrate these capabilities into regulatory workflows in a compliant and aligned manner that reflects evolving authority expectations. For sponsors, this provides access to the efficiency gains of AI adoption without the burden of building the governance and infrastructure required to deploy it responsibly.

The human element remains essential. Regulatory intelligence, however efficiently gathered, requires expert interpretation and contextual judgment, grounded in both global requirements and local implementation practices, as well as the experience-based knowledge developed over time. The value of AI in this space lies in its ability to amplify that expertise, not replace it.

Building for what comes next

The regulatory environment facing drug developers is not temporary. Divergence across markets will persist and the pace of change is unlikely to slow. New modalities, evolving safety expectations and shifting geopolitical conditions will continue to introduce complexity.

Organisations that manage this most effectively will treat regulatory capability as a strategic asset rather than an operational burden. This requires investment in expertise and structures that support flexibility over time.

FSP models offer a proven mechanism for building that capability. By combining centralised intelligence with locally embedded expertise and scalable resources, they help organisations stay ahead of change rather than react to it.

In an environment defined by uncertainty, the ability to move quickly and decisively is no longer just an advantage. It is a requirement for sustained success.


Myriam Antoun is Functional Lead, Regulatory Affairs, PPD FSP Solutions, part of the PPD clinical research business of Thermo Fisher Scientific