How Diligent meets regulatory requirements

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Sponsors routinely outsource vendor qualification audits to qualified third-party auditors. ICH E6(R3) Section 3.6.6 permits sponsors to transfer trial-related activities—including auditing—to service providers, provided that qualified individuals perform the work (Section 3.4). Importantly, delegating an activity does not transfer the sponsor’s regulatory responsibility and accountability. This is a well-established industry practice.

That is what a Diligent audit report represents. Diligent Pharma assigns qualified, independent GxP auditors to conduct the same comprehensive qualification audit that your organization would otherwise conduct internally or commission from another qualified auditor. The deliverable is the same—a thorough, independent assessment of the vendor’s Quality Management System, SOPs, regulatory compliance posture, and operational capabilities. The only difference is that instead of each sponsor separately commissioning an auditor to produce the same assessment of the same vendor, Diligent’s auditor conducts the qualification audit once, independently, and the report is made available to any sponsor who needs it.

Regulatory agencies do not require you to physically step into a vendor’s facility or to generate the qualification data yourself. They require objective, verified proof that the vendor is fit for purpose (Section 3.6.10) —and they require that you, as the sponsor, actively evaluate that proof and document your qualification decision.

The table below summarizes the requirements that support this approach and how a reviewed, accepted third-party report satisfies them.

Requirements

Requirements

What It Requires

What It Requires

How This Is Satisfied

How This Is Satisfied

ICH E6(R3) § 3.6.6

Sponsor QA’s independent review and documented acceptance decision preserves this accountability.

Delegating trial-related activities to a service provider does not transfer the sponsor's ultimate responsibility.

ICH E6(R3) § 3.6.7 & 3.6.8

Sponsor must assess service-provider suitability and have access to relevant information (e.g., SOPs, performance data) for selection and oversight.

The Diligent qualification package and audit report supply this information directly.

ICH E6(R3) Principle 7

Trial processes should be proportionate to risk and importance of the data, avoiding unnecessary burden.

Reusing a rigorous, independent audit avoids a redundant, duplicate audit of the same vendor.

ICH E6(R3) § 3.9.5

Oversight measures should be fit for purpose and proportionate to trial complexity and risk.

A documented gap assessment ties the report's scope to the Company's specific risk profile.

ICH E6(R3) § 3.10 / Appendix C

Sponsor must identify critical-to-quality factors and retain essential records, including documentation that service providers are suitably qualified.

The accepted report and Sponsor QA’s evaluation are retained as the essential-record documentation.

EU CTR 536/2014, Art. 71

Sponsors may authorize third parties to perform trial-related duties; ultimate responsibility for compliance remains with the sponsor.

Consistent with the Company's retained-accountability model for delegated activities.

Industry Precedent

Shared/consortium audit models (e.g., Rx-360, APIC) are an established practice for reusing independent qualification audit reports across multiple companies.

The Diligent model applies the same shared-audit principle to GCP vendor qualification.

Citations reflect ICH E6(R3), Step 4, adopted January 2025. Confirm current effective dates and any regional adoption status before use in a specific submission or inspection response.

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