This is a variation of the main consent set
Use the Finland Patient Information and Consent Requirements guide for the ordinary information, privacy, insurance and signature content. The emergency variation changes timing and creates a later-consent sequence. It does not reduce the information that must ultimately be provided.
Conditional. Use Article 35 only when every regulatory condition is built into the protocol and approved. Poor planning, investigator availability or a short recruitment opportunity is not an emergency situation under the Regulation.
Conditions for enrollment before consent
All of the following must apply:
- a sudden life-threatening or other sudden serious condition makes the participant unable to receive information and consent beforehand
- a direct, clinically relevant benefit is scientifically expected for that participant
- the legal representative cannot receive all information and consent within the therapeutic window
- the investigator is not aware of a previously expressed objection to trial participation
- the trial relates directly to the condition causing the emergency and can only be conducted in emergency situations
- the trial presents minimal risk and minimal burden compared with standard treatment for the condition
The decision to include the participant is made at the time of the first intervention and in accordance with the approved protocol.
Required Part II documents
Prepare:
- a Finnish and/or Swedish description of the emergency recruitment and consent procedure
- a method for identifying, confirming and documenting the urgency and therapeutic window
- the participant information sheet and consent form used as soon as the participant can decide
- the legal-representative information sheet and consent form used when the representative is available first
- age-appropriate documents for minors when relevant
- adapted documents for adults with reduced capacity when relevant
- staff instructions that distinguish trial documentation from urgent clinical care
Complete the current EU Recruitment and Informed Consent Procedure template and explain the Finland-specific roles, timing and records. Submit blank documents. They are not signed at CTIS submission.
Initial enrollment and documentation
The source record should show the sudden serious condition, why the participant could not be informed, why the representative could not be reached in time, the therapeutic window, the direct-benefit basis, the investigator's check for prior objections and the time of the first intervention.
Do not create a consent form that retrospectively states the participant consented before enrollment. Record the lawful emergency inclusion separately, then use the approved later-consent form for continuation.
Information and consent after the intervention
For a minor or adult with reduced capacity, the investigator seeks representative consent without undue delay and provides information to both representative and participant as soon as possible.
For another adult, the investigator seeks consent without undue delay from the participant or representative, whichever can decide sooner. If the representative consents first, obtain the participant's own consent as soon as the participant becomes capable.
The later discussion must cover the intervention already performed, ongoing participation, risks, alternatives, follow-up, data and sample handling, compensation and the right to refuse continued participation. The participant or representative and the person receiving consent sign and date the approved form.
Later refusal or withdrawal
If the participant or representative does not consent to continued participation, stop further trial-specific activities except measures needed for safety or lawful data handling. Inform the person of the right to object to use of data already obtained in the emergency phase.
The approved documents and protocol should explain how the site records an objection and what data can still be retained under applicable law. Do not promise deletion that conflicts with safety, legal or scientific-integrity duties.
Finland's Article 30 simplified cluster-consent route is not available. Do not confuse non-objection in a cluster trial with emergency inclusion under Article 35.
Use the Finland limited-capacity consent guide or minor consent guide when those populations are included. Run the final package through the Finland patient-facing document QC checklist and return to the Finland CTIS hub.
Prepare the emergency-consent package in minutes
Official sources and resources
- Regulation (EU) No 536/2014, Article 35 and Annex I section L, consolidated 5 December 2022.
- Tukija, national Part II document requirements, guideline T/448/2026, Annex I section L, 7 May 2026.
- Tukija, Participant Information Sheet and Informed Consent Form template T/447/2026, 25 June 2026.
- EMA, ICH E6 Good Clinical Practice scientific guideline, current EU version effective 23 July 2025.
- Act on Clinical Trials on Medicinal Products 983/2021, English translation, sections 6, 13 and 14.
Last reviewed: 29 August 2026