Unicure's experience reveals a significant regulatory risk: the FDA can reverse its position on a pre-agreed Statistical Analysis Plan (SAP). Despite prior alignment on using a natural history control, the agency later told the company this approach was merely 'exploratory,' invalidating their filing strategy and shocking investors.

Novo Nordisk ran a nearly 4,000-patient Phase 3 Alzheimer's trial despite publicly stating it had a low probability of success. This strategy consumes valuable patient resources, raising ethical questions about whether a smaller, definitive Phase 2 study would have been a more responsible approach for the broader research ecosystem.

The FDA's new pathway for rare disease drugs, based on causal biology, is scientifically promising. However, the name "plausible mechanism" is a critical flaw. The term sounds weak, creating doubt for patients and giving payers powerful leverage to deny coverage by implying a lower standard of evidence.

The 'FDA for AI' analogy is flawed because the FDA's rigid, one-drug-one-disease model is ill-suited for a general-purpose technology. This structure struggles with modern personalized medicine, and a similar top-down regime for AI could embed faulty assumptions, stifling innovation and adaptability for a rapidly evolving field.

After a decade on the market and multiple shifts in endpoints, Sarepta's definitive Phase 3 study for its DMD drugs failed. This outcome casts doubt on the entire accelerated approval framework for slowly progressive diseases, where surrogate endpoints may not translate to clinical benefit, leaving regulators and patients in a difficult position.

Novo Nordisk's large semaglutide Alzheimer's trial failure highlights a critical design flaw: launching a massive study without first using smaller trials to validate mechanistic biomarkers and confirm central nervous system penetration. This serves as a cautionary tale for all CNS drug developers.

The FDA is predicted to approve new PARP inhibitors from trials like AMPLITUDE only for BRCA-mutated patients, restricting use to where data is strongest. This contrasts with the EMA's potential for broader approvals or denials. This highlights the diverging regulatory philosophies that create different drug access landscapes in the US and Europe.

The FDA is shifting policy to no longer allow reliance on immunogenicity data (immunobridging) for approving new or updated vaccines. This move toward requiring full clinical efficacy trials will make it harder to combat evolving pathogens and would have prevented past approvals of key vaccines like those for HPV and Ebola.

Modernizing trials is less about new tools and more about adopting a risk-proportional mindset, as outlined in ICH E6(R3) guidelines. This involves focusing rigorous oversight on critical data and processes while applying lighter, more automated checks elsewhere, breaking the industry's habit of treating all data with the same level of manual scrutiny.