Sponsors of studies that fall under more than one EU regulation have a new practical reference. On 11 September 2026, the European Commission’s Directorate-General for Health and Food Safety (DG SANTE) published the COMBINE Project 2 sponsors’ guide on safety reporting in combined studies. The guide is endorsed by the Clinical Trials Coordination and Advisory Group (CTAG) and the Medical Device Coordination Group (MDCG). It is not legally binding and does not represent the Commission’s official position.
The problem
“Combined studies” fall under two or more of these regulations:
- the Clinical Trials Regulation (EU) No 536/2014 (CTR)
- the Medical Devices Regulation (EU) 2017/745 (MDR)
- the In Vitro Diagnostic Medical Devices Regulation (EU) 2017/746 (IVDR)
Each regulation sets its own definitions, documentation, timelines and processes for serious adverse events (SAEs) and device deficiencies (DDs). Until a dedicated legal framework exists, sponsors must reconcile all of them in parallel.
What the guide does
It builds on the earlier COMBINE analysis report and:
- sets a common definition of seriousness that works across all three regulations
- clarifies what investigators and sponsors each have to do
- recommends a single protocol that integrates the Clinical Investigation Plan (CIP) or Clinical Performance Study Plan (CPSP)
- maps communication flows between sponsors in multi-sponsor studies
- lists national reporting routes in Annexes 1 and 2
Open issues
The guide states that double reporting remains unresolved and requires legislative harmonisation. The MDR and IVDR also do not provide for urgent safety measures outside a substantial modification. Reporting to ethics committees is out of scope.
Source: CTAG, MDCG





