Recommendations for generating real-world evidence with regulatory-grade relevance and reliability

Real-world data (RWD) and real-world evidence (RWE) are increasingly incorporated into regulatory decision-making to complement randomized controlled trials (RCTs), particularly in settings where conventional trial designs are infeasible, such as rare diseases, rare molecular subtypes, and post-marketing evaluation. Across regulatory authorities, the use of RWD/RWE is consistently framed by the fit-for-purpose principle, centered on two foundational concepts: relevance and reliability. However, the absence of operational guidance has created uncertainty regarding how academic registries and healthcare databases can be designed or upgraded to meet regulatory expectations. Drawing on practical experience with disease registries in Japan and their regulatory applications, this review proposes a purpose-oriented framework clarifying the levels of relevance and reliability required according to specific regulatory objectives. We categorize considerations into three use cases: (1) drug development for rare diseases and rare molecular subtypes; (2) Pharmacovigilance; and (3) evidence generation for clinical questions that cannot be sufficiently evaluated through randomized controlled trials (RCTs). For each category, we outline essential requirements related to study design, data elements, quality management, governance, statistical planning, and operational feasibility. We further compare regulatory expectations across the U.S. Food and Drug Administration (FDA), the European Medicines Agency (EMA), the Pharmaceuticals and Medical Devices Agency (PMDA), and the International Council for Harmonisation (ICH). While international convergence is evident at the level of principles, operational thresholds and implementation frameworks differ. By articulating relevance and reliability as a shared regulatory language and emphasizing purpose-driven design and early regulatory engagement, this review provides practical recommendations for generating regulatory-grade RWE that meaningfully informs regulatory decision-making while complementing conventional clinical trials.

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Publication Details

Journal
International Journal of Clinical Oncology
Published
2026-08-20
DOI
https://doi.org/10.1007/s10147-026-03160-6
Primary Topic
Pharmacovigilance and Adverse Drug Reactions
Type
article
Field-Weighted Citation Impact
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article

Recommendations for generating real-world evidence with regulatory-grade relevance and reliability

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International Journal of Clinical Oncology
Pharmacovigilance and Adverse Drug Reactions
article

Recommendations for generating real-world evidence with regulatory-grade relevance and reliability

Hideaki Takahashi, Koji Oba, Atsushi Ohtsu, Taro Ueno, Toshihiro Misumi, Ryosuke Annaka, Akinori Yuri, Yasutoshi Sakamoto, Jun Okui, Yoshihiro Aoyagi, Takayuki Yoshino, Eri Tajima, Tomohiro Kuroda, Hiroki Sokuoka, Harumasa Nakamura, Rie OTAKE, Kenichi Nakamura, Yukiko Mori, Yasunari Sadatsuki, Makoto MIYAZAKI, Natsuko Okita, Hideaki Bando, Hiroki Yoshihara, Takayuki Nakamura, Keisuke Itoya, Kazuma Koizumi
article en

Abstract

Real-world data (RWD) and real-world evidence (RWE) are increasingly incorporated into regulatory decision-making to complement randomized controlled trials (RCTs), particularly in settings where conventional trial designs are infeasible, such as rare diseases, rare molecular subtypes, and post-marketing evaluation. Across regulatory authorities, the use of RWD/RWE is consistently framed by the fit-for-purpose principle, centered on two foundational concepts: relevance and reliability. However, the absence of operational guidance has created uncertainty regarding how academic registries and healthcare databases can be designed or upgraded to meet regulatory expectations. Drawing on practical experience with disease registries in Japan and their regulatory applications, this review proposes a purpose-oriented framework clarifying the levels of relevance and reliability required according to specific regulatory objectives. We categorize considerations into three use cases: (1) drug development for rare diseases and rare molecular subtypes; (2) Pharmacovigilance; and (3) evidence generation for clinical questions that cannot be sufficiently evaluated through randomized controlled trials (RCTs). For each category, we outline essential requirements related to study design, data elements, quality management, governance, statistical planning, and operational feasibility. We further compare regulatory expectations across the U.S. Food and Drug Administration (FDA), the European Medicines Agency (EMA), the Pharmaceuticals and Medical Devices Agency (PMDA), and the International Council for Harmonisation (ICH). While international convergence is evident at the level of principles, operational thresholds and implementation frameworks differ. By articulating relevance and reliability as a shared regulatory language and emphasizing purpose-driven design and early regulatory engagement, this review provides practical recommendations for generating regulatory-grade RWE that meaningfully informs regulatory decision-making while complementing conventional clinical trials.

International Journal of Clinical Oncology
Ministry of Education, Culture, Sports, Science and Technology (JP), Ministry of Health Labour and Welfare (JP), Pharmaceutical Research and Manufacturers of America (US), Osaka Kyoiku University (JP), Fanuc (Japan) (JP), Keio University (JP), Kyoto University (JP), Kyoto Medical Center (JP), National Cancer Centre Japan (JP), Mitsui Sugar (Japan) (JP), National Center of Neurology and Psychiatry (JP), MSD K.K. (Japan) (JP), Chugai Pharma (United States) (US), National Cancer Center Hospital East (JP), Kyoto University Hospital (JP), Japan Clinical Cancer Research Organization (JP), Flatiron Health (United States) (US), Japanese Foundation For Cancer Research (JP), Takeda (Japan) (JP), The University of Tokyo (JP), National Patient Safety Foundation (US)
Exact Sciences Corporation, Bristol-Myers Squibb, Pfizer, Nippon Shinyaku, Daiichi-Sankyo, Ministry of Health, Labour and Welfare, Eisai, Chugai Pharmaceutical, Daiichi Sankyo Europe, Medical and Biological Laboratories
Peace, Justice and strong institutions
Openalex Percentile: Top 11%
Pharmacovigilance and Adverse Drug Reactions
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