York Teaching Hospital NHS Foundation Trust provides a comprehensive range of acute hospital and specialist healthcare services for approximately 800,000 people living in and around York, North Yorkshire, North East Yorkshire and Ryedale - an area covering 3,400 square miles.
The Research & Development Office strive to increase the opportunities for patients and their families to be informed about, and involved in, our research and research processes.
Quick Reference Guides and Updates for New Clinical Trials Regulations from 28 April 2026
As the Trust moves to align our research activities with the new Clinical Trials Regulations which take effect from 28th April 2026, we have compiled a list of updates which we will be sharing throughout March 2026. A summary of these updates, including quick reference guides are below.
Please note this information is reference only, and advice should be sought from the Trust Research Advisor or Research Governance manager for research projects relating to the Trust.
1Amendments (Modifications) Updates and Quick Guide
As you are aware, the new UK Clinical Trials Regulations come into force at the end of April 2026.
Please read the below for an update on amendments (soon called modifications).
Please take a moment to read the information below - our SOPs will be updated accordingly.
The online Introduction to GCP Training is also being updated nationally to reflect the new regulations and should be finalised by the end of February. As soon as it’s available, we’ll let you know and ask all our staff involved in research delivery to plan time to complete the updated training. Sponsors will also begin asking for evidence of updated GCP, so we want everyone to be prepared as early as possible.
From 28 April 2026:
All changes to an approved CTIMP will be called modifications, not amendments.
Substantial amendments become Substantial Modifications.
Non‑substantial amendments become Modifications of an Important Detail (small but regulated changes).
MHRA had up to 35 days for substantial amendments.
Process was slower and more fragmented.
From 28 April 2026
Amendments become modifications.
MHRA will use a new streamlined review process.
The IRAS Modification Tool will be used instead of the Amendment Tool.
Turnaround times are intended to be quicker and more consistent.
The old vs new rules: Amendments vs Modifications (from 28 April 2026) are summarised below as quick reference guide.
OLD Rules (Before 28 April 2026)
NEW Rules (From 28 April 2026)
Terminology
Amendments
Modifications
Types
• Substantial Amendment • Non‑substantial Amendment • Minor Amendment
• Substantial Modification • Modification of an Important Detail • Minor Modification
Definition – Major Change
Substantial Amendment: significant impact on safety, scientific value, or conduct
Substantial Modification: same principle, updated definition under new regulations
Definition – Middle Category
Non‑substantial Amendment: smaller change but still needs review/notification
Modification of an Important Detail: new name; process clarified under new regs
Definition – Small Changes
Minor Amendment: administrative/typos, implemented immediately
Minor Modification: same principle; implemented immediately
Submission Tool for study sponsors
Amendment Tool in IRAS
Modification Tool (updated version of Amendment Tool)
Approvals Needed
Some require MHRA, some REC, some both
Same, but determined by Modification Tool, aligned to new streamlined rules
Submission Route for study sponsors
Amendment submitted via IRAS combined review (or separate if old processes still used by sponsor)
All Modifications handled through updated IRAS Modification Tool under the new UK Clinical Trials Regulations
Processing Times
MHRA: up to 35 days for amendments
Same timelines but aligned with combined review under revised clinical trials regulations. MHRA and REC now assess modifications together through combined review, so the process is smoother and more streamlined.
When Changes Can Be Implemented
Depends on whether substantial or not – site must check approvals
Must follow rules for Substantial Modifications; REC/MHRA approval needed before implementation
Regulatory Framework
Based on EU‑derived 2004 Regulations
Based on UK Clinical Trials Regulations 2026, new definitions, proportionate risk‑based approach
Applies To
Trials authorised before 28 April 2026 (“old rules trials”)
Trials authorised on or after 28 April 2026 (“new rules trials”)
Transitional Overlap
Both systems run in parallel: old‑rule trials follow amendments process, new‑rule trials follow modifications process
As part of the upcoming implementation of the new UK Clinical Trials Regulations at the end of April, we are sharing another key update that will impact how we deliver research across the Trust.
This update focuses on the new simplified consent provisions, which apply to specific lower‑risk CTIMPs.
Under the revised regulations, sponsors of eligible trials may use simplified arrangements for seeking and evidencing informed consent, replacing the default requirement for full written consent. These simplified arrangements are strictly limited to trials that:
Use licensed medicines,
Are given as part of routine NHS care, and
Do not require any extra procedures, tests or treatments solely for research purposes.
Where simplified consent is used, REC approval is still required, and sponsors must provide clear justification in their protocol along with details of how participants will be informed and how consent will be recorded. Evidence of consent may be captured more flexibly (e.g., documentation in clinical notes rather than a signed consent form), but this must be agreed in advance.
SOPs and training materials will be updated to reflect this change.
For now, please familiarise yourselves with the changes summarised below:
Not all studies qualify - this applies only to lower‑risk, authorised‑medicine trials delivered as part of routine care.
Sponsors must tell us explicitly if simplified consent is being used.
REC and MHRA remain responsible for approving its use.
Staff will be trained in the agreed consent procedure for each study.
Standard consent processes remain unchanged for all other studies.
OLD rules (Before April 2026)
UPDATED rules (From April 2026)
Consent terminology
Only standard informed consent recognised
Introduction of simplified arrangements for consentfor eligible lower‑risk trials
Who can use simplified consent?
Not permitted under old rules; full written consent always required except in very narrow emergency exceptions
Only allowed if ALL criteria met: • IMP already authorised in the UK • IMP used as part of routine care • No extra tests/interventions solely for research
Form of consent
Full written consent form required and signed by participant
Consent may be simplified (e.g., verbal) if approved byRECand documented appropriately (in clinical notes)
Evidence of consent
Signed consent form is the default requirement; filed in ISF + medical notes
Evidence can be proportionate: e.g., clinician’s note, simple tick‑box record, short script, depending on REC approval and protocol detail
Participant information
Full PIS required
Concise, proportionate information allowed - shorter leaflets, verbal explanations, digital info etc.
Protocol requirements
Standard consent description only
Sponsor MUST justify simplified consent and include: • reason for using simplified method • information provided to participant • how information is delivered • how consent is recorded
REC role
REC checks consent meets set standards
REC must assess if simplified consent is ethically appropriate; HRA advisory group being established for support
Legal basis
CT Regulations 2004 (written consent standard)
New UK Clinical Trials Regulations allow simplified consent for lower‑risk CTIMPs; part of wider regulatory reform
Applicability
Applies to all CTIMPs equally
Applies only to eligible lower‑risk trials; standard consent remains unchanged for all others