What Shapes EU Phase I Gene Therapy CTIS Timelines?
Clinical Trial Intelligence

What Shapes EU Phase I Gene Therapy CTIS Timelines?

20 July 2026

Across 51 Phase I gene therapy trials, the median end-to-end European Union Clinical Trials Information System (EU CTIS) review was 84 days, with a standard deviation (SD) of 61.2 days. Country-specific Part II timelines were substantially longer and more dispersed, with a pooled median of 259.5 days and SD of 253.7 days. Orphan-designated trials had the clearest faster-review signal, while AAV-based, pediatric, larger-sample, CNS-delivery, and October–December submissions were more frequently associated with ≥90-day reviews.

Trials
51
Phase I gene therapy
End to end
84 days
Median · SD 61.2
Part II
259.5 days
Pooled median · SD 253.7
≥90 days
49.0%
25 of 51 trials

How long did end-to-end EU CTIS review take?

End-to-end review, measured from initial EU CTIS submission to first authorization, had a median of 84 days, mean of 82.7 days, SD of 61.2 days, and range of 1–293 days.

Cumulative authorization rate
Within 30 days27.5% · 14/51
Within 60 days43.1% · 22/51
Within 90 days51.0% · 26/51
Within 120 days72.5% · 37/51
Within 180 days94.1% · 48/51
Pooled Phase I gene therapy trials; no analysis by authorization year.
Interpretation

The 84-day median sits close to the three-month threshold: 56.9% of trials took at least 60 days and 49.0% took at least 90 days. Most reviews were completed by six months, but a small right tail materially increased variability.

How did country-specific CTIS Part II timelines differ?

CTIS Part II is country-specific; end-to-end review is therefore not assigned to individual countries. Across country observations, the pooled Part II median was 259.5 days with SD 253.7 days. Among countries with at least five observations, the Netherlands had the shortest median at 34.5 days, while Spain had the longest at 554.0 days.

Country-specific Part II processing time, days
Country n Median Sample SD
Finland 1 4.0
Netherlands 10 34.5 282.7
Norway 1 89.0
Sweden 3 98.0 347.5
Ireland 2 144.0 168.3
Slovenia 1 154.0
Belgium 6 192.0 324.7
Italy 13 245.0 229.6
France 16 249.0 258.1
Germany 8 303.0 147.5
Poland 2 349.0 465.3
Spain 15 554.0 245.9
SD is not calculated for countries with one observation. Country values reflect CTIS Part II submission to the recorded country decision or authorization.
Interpretation

Country selection can materially change Part II exposure. The Netherlands combined the shortest robust median with high dispersion, whereas Spain, Germany, France, and Italy showed substantially longer central timelines. Large SDs indicate that country medians should be used as planning benchmarks rather than fixed expectations.

Which factors were associated with faster EU CTIS authorization?

A trial was classified as faster than median when its end-to-end review was below 84 days. Orphan status produced the strongest and statistically supported univariate signal: 71.4% of orphan trials were faster than median versus 33.3% of non-orphan trials.

Faster-review signals
Orphan designated
35 days
Median · 15/21 below median (71.4%)
Lenti or retroviral ex vivo
25 days
Median · 6/7 below median (85.7%)
July to September submission
27 days
Median · 8/13 below median (61.5%)
Planned sample 16 to 30
35 days
Median · 10/15 below median (66.7%)
Interpretation

Orphan status was associated with a 78-day lower median than non-orphan trials and a lower ≥90-day delay rate of 28.6% versus 63.3%. This was the clearest univariate association in the cohort. Vector, submission timing, and sample-size signals were directionally strong but should be interpreted as descriptive because subgroup sizes were smaller.

Which factors were associated with two and three month delays?

Overall, 29 of 51 trials (56.9%) took at least 60 days and 25 of 51 (49.0%) took at least 90 days. The strongest descriptive ≥90-day delay concentrations occurred in CNS-delivery, local or intratumoural, larger-sample, AAV-identified, pediatric, and October–December submission groups.

Share with end-to-end review ≥90 days
CNS delivery83.3% · 5/6
Local or intratumoural delivery75.0% · 3/4
Planned sample 31+66.7% · 8/12
Non-orphan63.3% · 19/30
October to December submission61.5% · 8/13
AAV identified61.1% · 11/18
Pediatric trial60.0% · 12/20
Interpretation

Delivery complexity and product class appear more informative than simple operational scale. CNS-delivery trials had a 113.5-day median and local or intratumoural trials 116.5 days, compared with 81 days for intravenous delivery. Pediatric trials also had a longer median than adult-only trials, 109 versus 74 days.

Did more countries and sites independently predict delay?

Direct monotonic relationships were weak: total sites had Spearman ρ=0.07, number of countries ρ=0.14, and planned sample size ρ=0.15. These values indicate limited standalone correlation with end-to-end EU CTIS duration.

Grouped operational benchmarks
One country
81 days
n=31 · 45.2% ≥90 days
Three or more countries
94.5 days
n=12 · 50.0% ≥90 days
One site
83 days
n=20 · 50.0% ≥90 days
Four or more sites
96 days
n=17 · 52.9% ≥90 days
Interpretation

Adding countries or sites modestly increased grouped medians but did not create a strong linear relationship. For planning, product characteristics, indication, orphan status, delivery route, and dossier timing appear more useful risk markers than country or site count alone.

Definitions and planning implications

End-to-end EU CTIS review: initial CTIS submission to first authorization. This is a trial-level measure and is not attributed to individual countries.

CTIS Part II: the country-specific assessment covering national and site-level requirements, measured from the earliest recorded Part II submission to the latest recorded country decision or authorization.

Planning implication: use 84 days as the pooled end-to-end central benchmark, but stress-test country Part II planning separately. For higher-risk profiles—non-orphan, AAV, pediatric, CNS/local delivery, larger planned samples, or October–December submissions—an internal buffer beyond 90 days is supported by the observed cohort.