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For Researchers

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).
  • Minor changes remain Minor Modifications.

The HRA confirmed that this terminology change applies to all studies under the new regulationsThe approvals process for modifications (amendments) - Health Research Authority

The key reasons for this change are:

Before 28 April 2026

  • Amendments are processed under old rules.
  • 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

 

 

2Simplified Consent Provisions - Lower-Risk CTIMPS

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 consent for 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 by REC and 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

 

Key links:

Simplified arrangements for consent in clinical trials - Health Research Authority

New report published on simplified arrangements for consent in clinical trials - Health Research Authority

 

 

Full MHRA & HRA guidance is still being finalised for this.

1st April 2024 – 31st March 2025

York & Scarborough

86 research studies open to recruitment

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5051 patients recruited into clinical trials