EMAExecution MethodologyRegulationHIGH INSPECTION RISK
EU GMP Annex 11

Computerised Systems

Establishes requirements for computerised systems used in GxP-regulated activities. Covers validation, data integrity, access control, audit trails, and disaster recovery. The EU counterpart to FDA 21 CFR Part 11.

LAST REVISED
June 2011
PRODUCT AREAS
SterileSolid DoseBiotechApi
SCOPE & APPLICABILITY

All GxP computerised systems in EU-regulated facilities including LIMS, DCS, SCADA, MES, ERP modules used for GxP purposes, and QMS software.

KEY REQUIREMENTS
  • 01Risk-based approach to validation — system inventory with GxP impact assessment
  • 02Supplier assessment and ongoing monitoring for commercial off-the-shelf (COTS) systems
  • 03Validation documentation: URS, FS, CS, IQ, OQ, PQ with traceability matrix
  • 04Data integrity controls: access management, audit trails, backup/restore procedures
  • 05Change management — all changes go through formal change control with impact assessment
  • 06Periodic review of validated systems — evidence of continuing validated state
IMPLEMENTATION TIPS
Maintain a GxP system inventory with impact classification — this is the audit starting point
Supplier qualification for SaaS/cloud systems needs specific clauses: data ownership, audit rights, incident notification
Audit trail review frequency must be documented in your data governance procedure
REVISION NOTES

Current version June 2011. Under revision — EU GMP Annex 11 rev draft expected 2025. Monitor EMA website. ISPE GAMP 5 (2022) is the primary implementation reference.

EU GMP Annex 11: frequently asked questions

Quick answers to common questions about EU GMP Annex 11.

What is EU GMP Annex 11?

EU GMP Annex 11 — Computerised Systems — is a regulation issued by the European Medicines Agency (European Union). Establishes requirements for computerised systems used in GxP-regulated activities. Covers validation, data integrity, access control, audit trails, and disaster recovery. The EU counterpart to FDA 21 CFR Part 11.

Who does EU GMP Annex 11 apply to?

All GxP computerised systems in EU-regulated facilities including LIMS, DCS, SCADA, MES, ERP modules used for GxP purposes, and QMS software.

What are the key requirements of EU GMP Annex 11?

EMA EU GMP Annex 11 requires, among other things: Risk-based approach to validation — system inventory with GxP impact assessment; Supplier assessment and ongoing monitoring for commercial off-the-shelf (COTS) systems; Validation documentation: URS, FS, CS, IQ, OQ, PQ with traceability matrix; Data integrity controls: access management, audit trails, backup/restore procedures.

When was EU GMP Annex 11 last updated?

The current version of EU GMP Annex 11 dates from June 2011. Current version June 2011. Under revision — EU GMP Annex 11 rev draft expected 2025. Monitor EMA website. ISPE GAMP 5 (2022) is the primary implementation reference.

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When EU GMP Annex 11 — or any GxP requirement — is revised, recalled against, or clarified by new guidance, the Weekly GxP Briefing surfaces it. Free, one email a week.

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