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Dec 22, 2025 | Vicki Cookson

The upcoming eCTD 4.0 health authority (HA) requirements represent a fundamental shift from a document to data-based approach to submissions. Universal deadlines are quickly approaching, starting with Japan in April 2026 and the EMA for Centrally Authorized Products (CAPs) in 2027.

To accelerate compliant submissions, a centralized data foundation can help regulatory teams navigate eCTD 4.0’s complex new data standards. “These new data concepts present opportunities for speed, but also introduce a new challenge. If you don’t have a unified RIM system or a data strategy, your risk of non-compliance increases,” says Vicki Cookson, senior director, Veeva RIM strategy at Veeva.

Key new data concepts of eCTD 4.0

As regulatory teams manage and monitor an increasing quantity of data, eCTD 4.0 mandates a need for increased data governance and stewardship. eCTD 4.0’s approach replaces the rigid folder structure and leaf element concept of eCTD 3.2 with a more dynamic message structure.

This new structure relies on code lists while introducing new concepts, including:

  • Context of Use (CoU) and associated keywords: Communicates to health authorities why a document is included and where it belongs.
  • Data reuse via metadata: Enables one-time document submission with the ability to reference it in future submissions.
  • Many-to-many lifecycle management: Simplifies complex updates, such as manufacturing changes, while maintaining clear traceability.

To address data complexity and proactively meet the governance and stewardship requirements of both eCTD 4.0 and IDMP, organizations are adopting unified RIM platforms. “In the context of external data standards and organizations, you need to ensure that the application landscape that you’re working in reflects those data standards and the flow of data across different systems for maintaining compliance,” says Navpaul Cheema, regulatory senior manager at Veeva.

Messy data leads to flawed submissions

The fundamental shift towards data in eCTD 4.0 makes consistent data quality critical for avoiding bottlenecks during the submission process. Global HAs actively encourage a robust data strategy to manage this risk, as Cookson explains: “If your data is inconsistent or messy, even if the document itself is perfect, your submission is flawed.”

Regulatory teams must share a common understanding of terminology and keywords for managing data integrity. “If two colleagues working in a submission enter slightly different terms, such as ‘mouse’ and ‘mice,’ the submission becomes broken,” emphasizes Cookson.

New operational challenges also undermine data quality, such as errors due to retrieving data across multiple, disconnected systems or manually replicating RIM data into separate publishing tools. Seemingly inconsequential mistakes can break the submission’s data backbone and trigger validation failure.

Regulatory teams can improve data quality and governance by using a unified RIM platform for managing submission lifecycles. “A single source of truth provides the opportunity for automation, cascading data from the application level down to the submission. It makes the creation of new content, new applications, and amendments faster and more reliable,” says Cookson. With a single source of truth for submission data and documents, regulatory teams have greater visibility, control, and traceability for meeting compliance.

“Without centralized enforcement, the flexibility of eCTD 4.0 becomes its greatest weakness. With a single unified RIM platform, regulatory operations, regulatory affairs, and reviewers all have one single source of truth,” notes Cookson.

Increasing agility for same-day submissions with unified RIM

eCTD 4.0’s shift to a data-centric model provides the opportunity to increase agility and enable same-day submissions. “It provides the opportunity to accelerate submission processes with better quality, ensuring compliance,” says Vicki Cookson. By leveraging continuous publishing on a unified RIM platform, eCTD 4.0’s core benefits — metadata clarity, document flexibility, and data reuse — help eliminate the publishing bottleneck, ultimately delivering medicines to patients faster.

To prepare for eCTD 4.0 and realize its benefits, organizations should consider three core elements:

  • Governance: Enable change management and training, establishing the necessary control over submission details for data consistency.
  • Strategy: Teams must establish clear rules for sender-defined keywords and CoU standards, integrating this strategy directly into their RIM system.
  • Control: A unified system eliminates redundant data entry, cross-system friction, and aligns regulatory functions with other business functions.

When these elements are integrated with a unified RIM platform, eCTD 4.0 is capable of consistently delivering same-day, compliant submissions.

See how OM Pharma harmonized data and accelerated regulatory processes with unified RIM.

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