Investigational New Drug (IND) Application | Process and Requirements

Learn about the Investigational New Drug (IND) application, its purpose, process, types and regulatory requirements in pharmaceutical drug development
The process of developing a new drug is very complicated and regulated so we can be sure that the drug is going to be safe and work properly in the patient population. The first step in the IND application process is to submit an IND application.
Investigational New Drug (IND) Application
After a company has completed enough lab/safety testing and animal studies, the IND will allow them to conduct their clinical trials in people for research purposes, as well as providing a mechanism for the regulatory body of the IND to approve the IND application for investigational use of drugs on patients.

The U.S. FDA and comparable organizations in other countries (such as EMA in Europe and CDSCO in India) have established regulations for submitting IND applications. Therefore, all persons involved with Developing Drugs (including Drug Developers, Clinical Research and Drug Regulatory Affairs) need an understanding of submitting an IND application.

What is an Investigational New Drug (IND) Application?

The IND application permits the pharmaceutical company to apply to the appropriate regulatory entity for permission to commence the clinical testing of a drug not previously approved by the FDA. After demonstrating through pre-clinical studies that the drug appears to be safe enough for use in humans as part of a clinical trial, the drug developer must prepare and submit the IND application to the appropriate regulatory entity (e.g., the FDA or EMA).

In addition to providing ethical guidelines for conducting research on human subjects, IND also provides state and federal governments with information related to the drug including:
- Preclinical studies
- Manufacturing
- Protocols for conducting clinical studies
- Qualifications of Principal Investigational Staff
When submitting the IND application, the manufacturer is requesting permission from regulatory agencies to conduct human trials of this drug.

Types of IND Applications

IND Applications that fall within one of four major types based on the intended purpose of the clinical study.

1. Commercial INDs

A Commercial IND is submitted by a sponsor (e.g., pharmaceutical company) that intends to manufacture and sell the drug after successful completion of the clinical study; therefore, this is the most common type of IND application submitted to the FDA.

2. Investigator INDs

An Investigator IND is submitted by the principal investigator who is both sponsoring and conducting the clinical study. An investigator submitting an IND will be responsible for all regulatory compliance as the sponsor.

3. Emergency Use INDs

Emergency Use INDs (EINDs) permit the use of investigational drugs to treat patients with a life-threatening illness in which no adequate alternative therapies exist. EIND allows for rapid access to potentially life-saving therapies for patients in otherwise unavailable circumstances.

4. Treatment INDs

A Treatment IND permits the use of investigational drugs in the treatment of patients who have a serious disease or condition and who otherwise would not qualify for participation in the ongoing clinical study of the investigational drug. Treatment IND may be used primarily for patients who have serious and/or life-threatening diseases (e.g., cancer, certain rare genetic disorders).

Key Components of an IND Application

As an IND submission to the FDA, it has several important, distinct sections to ensure that the FDA has a complete understanding of the investigational drug.

1. Preclinical Study Data

Taxes must be assessed via laboratory/animal studies before any human studies take place.
These studies can determine:
  • Toxicity
  • Pharmacological behavior
  • Dosing and metabolism of the drug
  • Safe dosage limit for a drug
Preclinical studies must demonstrate that an investigational drug is reasonably safe to be used in human trials.

2. Chemistry, Manufacturing and Control (CMC)

The CMC section of your entity’s application will describe how the entity has manufactured, tested and retained appropriate controls over the drug.
It will contain:
  • Information on the drug’s composition
  • A description of the drug manufacture
  • Data demonstrating the drug’s stability
  • A description of the quality controls used in the manufacture of the drug
The purpose of this information is to ensure the entity is consistently producing the investigational drug at the appropriate quality.

3. Clinical Protocols

Clinical protocols describe how the study will be performed.
Key elements contained in this section include:
  • Study design
  • Patient eligibility criteria
  • Plan of dosage
  • Plan of monitoring
  • Designating safety endpoints
The purpose of this section is to demonstrate that the study is scientifically sound and ethically conducted.

4. Investigator Information

Sponsors will be required to submit information about the clinical investigators that will be involved in the trial.
This information shall include:
  • Qualifications
  • Clinical experience
  • Review and approval by IRB
The clinical investigator must be qualified to ensure that the study is being conducted in a safe manner and in accordance with ethical standards.

Review Process for Investigational New Drug

A regulatory authority will review and assess an IND application to be able to determine whether to proceed with clinical trials.
Usually, the FDA has a 30 day period after submission to review an IND application.
Multiple actions can occur during the Regulatory Authority’s review period:
1. Approve an IND and allow clinical trials to begin.
2. Request additional information for sufficient review.
3. Place the clinical trial on clinical hold due to safety.
Once there are no objections made during the review period, the sponsor may begin the clinical trial phase of the drug development.

Phases of Clinical Trials Post IND Approval

Clinical trials are conducted in phases when the IND becomes effective.
Phase I- Assess safety through testing in small groups of healthy participants.
Phase II- Evaluate efficacy (how well the drug works) in an appropriate patient population. The safety and side effects are also assessed.
Phase III- Assess efficacy in large-scale clinical trials. Compare the drug to available treatments.
Once the IND application has been successfully completed and all clinical trial data is collected, the sponsor can submit a New Drug Application (NDA) to receive FDA marketing approval.

IND Safety Reporting Requirements

It is essential for sponsors to consistently keep track of the safety of their subjects during their clinical trials.
The essential format of reporting includes:
  • Adverse Event Reports.
  • Annual Progress Reports.
  • Protocol Amendments.
  • Safety Updates.
These reports will provide the regulators with an ongoing confirmation that they are providing safe protection for trial participants.

Challenges in IND Preparation

There are many scientific and regulatory challenges that need to be overcome in order to prepare a successful IND application.
Common types of issues experienced when preparing IND applications are:
  • Some Sponsors do not submit the appropriate amount of Preclinical Data.
  • Variations in Manufacturing Processes.
  • Poor clinical protocol design.
  • Insufficient Amount of Safety Data.
To help prevent these issues from delaying clinical trial progress, many sponsors conduct pre-IND meetings with the FDA or IRBs to discuss their development plans.

Importance of IND in Drug Development

The IND application is an essential step in the transition from laboratory study of potential new medicines to using them in human subject research.
If there were no regulatory framework in place for approving a drug as a candidate for clinical trial:
  • The safety of patients participating in those trials may be jeopardized.
  • Quality of the drug may not be adequately monitored.
  • There may be no assurance that scientific validity or integrity will be upheld during the trial.
Regulatory agencies review IND applications to identify both drugs with best prospects for success and also ones that appear reasonably safe; only those drugs will be permitted to enter the phase of human testing.

The IND application is an essential component of the pharmaceutical development process involving all investigational drugs; it provides patients with assurance that therapeutic products have been subject to rigorous scientific analysis prior to their exposure to humans as part of clinical trials.

The detailed submission of the development history and status of investigational drug candidates; manufacturing processes; preclinical evaluation of safety, efficacy, etc.; and clinical protocols constitute the IND system that protects patients from harm while stimulating innovative advances in medicines.

Knowledge of the IND process is essential for all organizations engaged in developing new therapies for progression through the pharmaceutical drug development "life cycle" from the laboratory into clinical practice and on to the patient population that will benefit from them.

Frequently Asked Questions on IND Applications


Q1. What is an IND application?

Answer: An IND is a request to lawfully allow for testing on humans.

Q2. Who submits an IND application?

Answer: IND Applications can be submitted to the FDA from research institutions, clinical research sites or pharmaceutical companies.

Q3. Which authority reviews IND applications in the US?

Answer: In the USA, the IND application will be filed with and reviewed by the FDA.

Q4. How long does IND review take?

Answer: An order will typically be received from the FDA within 30 days of submission.

Q5. What information is included in an IND?

Answer: An IND will include pre-clinical data, management and protocol and investigator and site info.

Q6. Can clinical trials start without an IND?

Answer: No human trial can begin without prior approval of an IND.

Q7. What happens after IND approval?

Answer: Once an IND is approved, a company will begin to conduct trials in phases 1, 2, 3, etc.

Q8. What is the difference between IND and NDA?

Answer: (I) An IND allows one to conduct clinical studies. (II) An NDA is the means by which approval will be obtained to provide the drug to market.


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Dr. Ankur Choudhary is India's first professional pharmaceutical blogger, author and founder of pharmaguideline.com, a widely-read pharmaceutical blog since 2008. Sign-up for the free email updates for your daily dose of pharmaceutical tips.
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