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Philippines FDA Clinical Trial Application Process: Administrative Order 2020-0010

How the Philippines FDA authorizes clinical trials under Administrative Order 2020-0010: the License to Operate prerequisite, the CTA and Import License applications, REC ethics review, and post-authorization SUSAR and reporting obligations.

The Philippines Food and Drug Administration (FDA), an agency of the Department of Health, is the national regulator responsible for authorizing and overseeing clinical trials of investigational drug products in the country. Its current governing framework is Administrative Order No. 2020-0010, “Regulations on the Conduct of Clinical Trials for Investigational Products”, issued in 2020. This guide explains what the AO covers, the licensing prerequisites a sponsor or CRO needs before it can apply, what a Clinical Trial Application (CTA) and Import License (IL) submission involves, and the ongoing reporting and inspection obligations that follow authorization. Where the publicly available FDA material does not specify a figure — a processing fee, a statutory review timeline — this guide says so rather than estimating, since sponsors should confirm current, transaction-specific figures directly with FDA’s Center for Drug Regulation and Research (CDRR) rather than relying on a secondary source.

What Administrative Order 2020-0010 covers

AO 2020-0010 states four objectives: full protection of the rights, safety, and welfare of trial subjects and the integrity of trial data through adoption of International Council for Harmonisation Good Clinical Practice (ICH-GCP) standards; an efficient and effective process for approving clinical trials; standards and requirements for regulating and importing investigational products; and strengthened monitoring of GCP compliance across sponsors, CROs, investigational sites, and Research Ethics Committees (RECs) through regulatory inspection. The order applies to organizations, institutions, and individuals conducting clinical trials of investigational products in the Philippines, and it explicitly builds the country’s framework on ICH-GCP rather than a bespoke local standard — a design choice that matters to any sponsor running the same protocol across multiple ICH-adhering jurisdictions, since it narrows (though does not eliminate) the local-specific adaptation a Philippine site requires.

Prerequisite: License to Operate (LTO)

Before a sponsor or Contract Research Organization (CRO) can submit a clinical trial application, AO 2020-0010 requires it to first hold a License to Operate (LTO) from the Philippines FDA in the relevant capacity — as a Sponsor and/or as a CRO. The LTO is a separate, prior authorization to operate in that role in the Philippines; it is not part of the trial-specific application itself, which means a sponsor entering the Philippine market for the first time needs to plan for this step ahead of, and independently from, its first CTA submission. A domestic legal presence or authorized local representative is typically expected as part of this process, consistent with how FDA licenses other regulated entities, though sponsors should confirm current LTO documentary requirements directly with FDA rather than assume a fixed checklist, since supporting circular guidance is updated more frequently than the parent AO.

The Clinical Trial Application (CTA) and Import License (IL)

Once the LTO is in place, the Sponsor, CRO, and/or Principal Investigator applies for the trial-specific authorizations:

  • Clinical Trial Application / Clinical Trial Approval (CTA) — authorizes the conduct of a clinical trial of an investigational drug product in the Philippines.
  • Import License (IL/ILA) — authorizes the importation of the investigational product and ancillary trial supplies needed to conduct the trial. Sponsors that will import investigational product apply for this alongside, or as part of the same submission workflow as, the CTA.

FDA’s published guidance during the COVID-19 period described submission of the clinical trial application, together with the documentary requirements set out under AO 2020-0010, to FDA via email as part of the process introduced at that time; sponsors should verify the current accepted submission channel (email versus an online portal) directly with FDA’s Center for Drug Regulation and Research, since this kind of operational detail is the sort of thing agencies update through circulars rather than by re-issuing the parent Administrative Order. This guide does not state a specific processing-day timeline or fee schedule for the CTA/IL review, because FDA’s publicly posted AO text does not fix one in a way this guide can verify independently — treat any timeline or fee figure you encounter elsewhere as provisional until confirmed against current FDA circulars or direct correspondence with CDRR.

Ethics review runs alongside FDA authorization

Consistent with ICH-GCP, a Philippine clinical trial also requires review and approval from a Research Ethics Committee (REC) registered with the Philippine Health Research Ethics Board (PHREB) or otherwise recognized for the purpose. FDA authorization and REC ethics review are separate approvals with separate reviewing bodies, the same two-track structure used in most ICH-GCP jurisdictions (compare, for example, Singapore’s HSA-plus-IRB structure or Canada’s Health Canada-plus-REB structure). A sponsor should not assume FDA authorization substitutes for REC approval, or vice versa; both are required before enrollment can begin at a given site.

Post-authorization reporting obligations

AO 2020-0010 sets out ongoing reporting duties that continue once a trial is authorized and underway, including:

  • Suspected Unexpected Serious Adverse Reaction (SUSAR) reporting — consistent with ICH-GCP safety reporting expectations, sponsors must report SUSARs arising during the trial.
  • Interim and annual reports — sponsors are required to submit periodic reports on trial status and safety over the course of the authorized trial.

FDA retains the authority to inspect investigational sites, sponsors, CROs, and RECs to confirm compliance with the approved protocol, GCP, and AO 2020-0010 itself — the same inspection-and-enforcement layer that sits behind most national clinical trial frameworks, giving the authorization a compliance tail that extends well past the initial approval date.

Where the Philippines fits in a multi-country Southeast Asian submission

For sponsors running the same protocol across several Southeast Asian and neighboring markets, the Philippines’ FDA-plus-REC, ICH-GCP-aligned structure sits alongside comparable but non-identical frameworks elsewhere in the region — see CASRAI’s guides to Singapore’s HSA CTA/CTN/CTC framework and Indonesia’s BPOM clinical trial approval process for direct comparison. As in those markets, a Philippine submission needs local licensing (the LTO) resolved before the trial-specific application can even be filed, which is an easy step to under-plan for on a multi-country timeline built around jurisdictions that don’t require an equivalent prior step.

Frequently asked questions

What is Administrative Order 2020-0010?

It is the Philippines FDA’s current Administrative Order governing the conduct of clinical trials for investigational products, titled “Regulations on the Conduct of Clinical Trials for Investigational Products.” It adopts ICH-GCP standards, sets the approval process for clinical trials, governs investigational product import, and establishes FDA’s compliance-monitoring authority.

Does the Philippines FDA require a separate ethics committee approval?

Yes. FDA authorization (the CTA) and Research Ethics Committee review are separate approvals from separate bodies, both required before a trial can enroll subjects, in line with ICH-GCP practice.

Who can apply for a CTA in the Philippines?

The Sponsor, CRO, and/or Principal Investigator can apply, but the applying entity must first hold a License to Operate (LTO) from FDA in the Sponsor and/or CRO capacity before the trial-specific CTA can be submitted.

Is there a separate application to import investigational product into the Philippines?

Yes. The Import License (IL/ILA) authorizes importation of the investigational product and ancillary trial supplies, and is applied for alongside the CTA process for trials that require importation.

What safety reporting does FDA require during an authorized trial?

AO 2020-0010 requires reporting of Suspected Unexpected Serious Adverse Reactions (SUSARs), along with interim and annual status/safety reports over the life of the authorized trial, consistent with ICH-GCP expectations.

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