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How to legally conduct a clinical trial in the Czech Republic

step-by-step

A clinical trial in the Czech Republic must be independently assessed by both SÚKL and at least one ethics committee — both weigh the risk-benefit ratio for patients and the scientific justification for the study. The trial can't start without both approvals, and the ethics committee additionally focuses on protecting participants' rights and informed consent. We explain the steps required to legally run a clinical trial in the Czech Republic.

Legal experts discussing clinical trial requirements in the Czech Republic.

Key takeaways

Every clinical trial in the Czech Republic is subject to strict EU regulations () and Czech law; the process is handled centrally via the .
Key risk: non-compliance can lead to fines of up to CZK 20 million, suspension of the trial, or even criminal liability; administrative and procedural details also involve many hidden costs.
ARROWS, a Prague-based law firm, has long-standing experience in handling regulatory matters and routinely assists clients with preparing documentation, representation before authorities, and ensuring compliance with all legal requirements under Czech legislation.
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What is a clinical study from a legal perspective

From a legal perspective, this means that state authorities, primarily the State Institute for Drug Control – SÚKL in the Czech Republic and the relevant ethics committee, must verify the safety of the study and the protection of patients' rights at every step. The lawyers at ARROWS law firm have been specialising in the regulatory field of medicinal products and clinical studies for over ten years and are familiar with the risks of the entire process.

Related questions on the legal definition and classification of studies

1. What is legally considered a clinical study?

A clinical study is defined as research involving a patient (subject) where the effect of a medicinal product or a therapeutic procedure is being tested. In case of doubt about the classification (e.g., whether it is a clinical trial or a non-interventional study), it is necessary to follow the interpretation of the SÚKL, which is the decisive authority in this matter.

2. Do legal requirements differ by study type (without a medicinal product, non-interventional study)?

Yes, the regulations differ fundamentally. Non-interventional (observational) studies, where the medicinal product is administered in accordance with its registration and diagnostic procedures do not go beyond standard practice, have a more lenient regime (only notification to the SÚKL, ethics committee approval depending on the site type), while interventional clinical trials are subject to the full approval process in the CTIS system.

3. Who is the 'sponsor' of the study according to the law?

The sponsor is a person (natural or legal), company, institution, or organisation that is responsible for initiating, managing, and financing a clinical trial. In practice, it pays to have contractual relationships and the liability framework addressed when establishing the sponsor's role, which falls under the area of contracts and negotiations. In a legal sense, the sponsor bears objective liability for the safety and scientific quality of the trial.
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Regulatory framework: What you need to know

In 2026, clinical studies in the Czech Republic are primarily regulated by the following legal acts:

  1. Regulation (EU) No 536/2014 of the European Parliament and of the Council (CTR) – a directly applicable regulation for the entire EU. This regulation has unified the application process through the CTIS portal and introduced strict rules for transparency and subject protection. For a broader context of changes in the healthcare sector regulation for 2026, the following overview of what is changing in the regulation of supplements and medicinal products in 2026 may also be useful.

  2. Act No. 378/2007 Coll., on Pharmaceuticals – the key Czech law that supplements the European regulation on matters left to the competence of Member States (e.g., specifics of the functioning of ethics committees, sanctions, language requirements).

  3. Act No. 372/2011 Coll., on Health Services – regulates the conditions for the provision of health services by the providers where the study is conducted.

What does this mean in practice? A failure in one of these areas means that the system will reject your application or the approval process will be significantly prolonged.

Step by step: The approval process

The first and absolutely crucial step is the registration of the sponsor in the CTIS (Clinical Trials Information System). All documentation is uploaded here, and there is no longer a "paper submission".

You must prepare extensive documentation divided into a scientific part (Study Protocol, Investigator's Brochure, documentation on the medicinal product) and a national part (Informed Consent, recruitment procedures, insurance). For the informed consent and the processing of participants' sensitive data, it is advisable to simultaneously review the data protection setup according to GDPR. In parallel, you must ensure cooperation with the relevant ethics committee in the Czech Republic, which will assess the study as part of the national part of the application.

Application submission and validation

After uploading to CTIS, a 10-day period for application validation, i.e., a completeness check, begins. If the SÚKL finds deficiencies, it will ask you to supplement the application, for which you have a maximum of 10–15 days depending on the type of deficiency; if you miss the deadline, the application automatically lapses.

Application assessment

The standard period for assessment is 45 days from validation, and this period may be extended if the regulator raises questions (RFI). You usually have only 12 days to respond, which requires a deep knowledge of regulatory standards and the ability to communicate with the authority accurately and quickly.

At this stage, the ethics committee assesses the ethical aspects of the research, patients' rights, and the clarity of the informed consent. Its opinion is binding for the final decision in the Czech Republic.

Contractual arrangements and approval at the trial site

While the process is ongoing in CTIS, you must conclude clinical trial agreements with individual healthcare facilities (sites). Although these contracts are not subject to direct approval in CTIS, the study cannot be practically initiated without them, and this is often where the hospital's legal department gets involved.

Decision and site activation

Once a positive decision is issued in CTIS (including the opinion of the SÚKL and the ethics committee), the study is authorised in the Czech Republic. Subsequently, the sponsor must notify the date of the start of subject recruitment in the CTIS system.

Related questions on the approval process

1. How long does the entire approval process take?

Thanks to the fixed deadlines in Regulation 536/2014, the process usually takes 60 to 106 days (including query rounds). The process is more predictable than in the past, but it places extreme demands on the sponsor's speed of response.

2. Can I start the study if the SÚKL agrees but the ethics committee has reservations?

No. A single decision is issued for the Czech Republic. If the ethics committee's opinion on Part II is negative, the overall decision for the Czech Republic will be a refusal.

3. What is an EU CT Number?

It is a unique study identification number generated by the CTIS system (previously, the EudraCT number was used). Without this number, the study does not legally exist.
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Rights and obligations of study participants

In a legal sense, every participant (subject) in the study must be properly informed and must sign an Informed Consent form approved as part of the application. The document must be in Czech, understandable to a layperson, and must not contain legal loopholes that absolve the sponsor of liability.

Participation must be voluntary, without coercion or inadequate financial motivation that could influence judgment. A participant may withdraw from the study at any time without giving a reason and without penalty.

The sponsor must have liability insurance for damages arising in connection with the clinical trial. This insurance must be valid for the entire duration of the study in the Czech Republic.

A breach of these obligations means not only a procedural error but also potential civil liability for compensation for harm.

Risks and sanctions

How ARROWS helps (consultation@arws.cz)

Rejection of the study (Lapsed application): If you fail to respond to queries in CTIS within the short deadline (e.g., 12 days), the authorisation application automatically lapses.

Preparation and deadline monitoring: The lawyers at ARROWS monitor procedural deadlines and help formulate correct responses to SÚKL's comments.

Fine of up to CZK 20 million: Conducting a clinical trial without authorisation, or a serious breach of the sponsor's obligations, is punishable by a fine of up to CZK 20,000,000 under the Act on Pharmaceuticals.

Compliance and representation: ARROWS law firm conducts audits of compliance with the Act on Pharmaceuticals and represents clients in proceedings before the SÚKL.

Liability for harm to health: If a study participant suffers harm to their health and the sponsor does not have properly arranged insurance or contracts, there is a risk of lawsuits for damages in the millions.

Contractual agenda and insurance: We review insurance policies and prepare clinical trial agreements to clearly define liability relationships.

Illegal conduct of a study: Starting a study before the formal notification in CTIS or continuing after its suspension is a serious offence.

Legal supervision: We ensure that all formal steps (notification of start, end, suspension) are carried out in the CTIS system on time.

Suspension of the study by the regulator: The SÚKL has the power to immediately suspend a study for safety reasons. This results in huge financial losses and reputational risk.

Crisis management: In the event of a threatened suspension, we immediately negotiate with the regulator and propose corrective measures.

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Ensuring safety and transparency

One of the sponsor's key obligations is to ensure that the study is monitored and data are reported transparently. The sponsor must ensure adequate monitoring of the study's conduct on-site, where monitors (CRAs) verify compliance with the protocol and Good Clinical Practice.

The sponsor has an obligation to immediately report all Suspected Unexpected Serious Adverse Reactions (SUSARs) to the EudraVigilance database. Ignoring this obligation is a serious administrative offence.

Archiving is also important, where both the sponsor and the investigator must retain the documentation (Master File) for at least 25 years after the end of the clinical trial. In practice, these are complex procedures requiring precision, which the lawyers at ARROWS address by setting up processes in the contractual documentation with CROs and research sites.

Related questions on monitoring and safety

1. Who is liable if a CRO fails?

Legally, the responsibility for the study remains with the sponsor, even if they have delegated activities to a CRO. Therefore, a high-quality contract between the sponsor and the CRO, which allows for recourse claims, is crucial.

2. What happens if a monitor discovers that a research site is violating the protocol?

The sponsor must immediately take corrective action. If the violation is serious and persistent, the sponsor must terminate the site's participation in the study and inform the SÚKL.

3. To whom do I report Serious Breaches?

The sponsor must report any serious breach of the protocol or the regulation that may affect the safety of subjects or the scientific value of the data via CTIS within 7 days.
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Special aspects: Vulnerable populations

If you are planning a study that includes so-called vulnerable subjects (for example, minors, persons with limited legal capacity, persons in emergency situations), the CTR and the Act on Pharmaceuticals impose specific requirements.

For minors or persons incapable of giving consent, the consent must be signed by a legal representative (parent, guardian).

Even a minor must receive information appropriate to their age, and their opinion must be taken into account, with the minor's dissent being respected. Studies on vulnerable populations must usually have a direct health benefit for the participant or must be associated with only minimal risk and burden.

It is precisely these rules that are very sensitive, and their violation is not only a breach of the law but also of ethical standards, which can lead to the immediate halt of the study.

International aspects and the ARROWS International network

Most modern clinical studies are multicentric and take place in several EU states. Thanks to the CTIS system, you submit a single application for all states, but national specifics, such as contracts, insurance, or ethics committees, remain different in each country. ARROWS law firm has a worldwide network of partners (ARROWS International), which allows for effective legal support in international clinical studies and the handling of local requirements in other jurisdictions.

Conclusion

Conducting a clinical study in the Czech Republic is a process that, although centralised thanks to digitalisation (CTIS), carries a number of legal risks and strict deadlines. Errors in document preparation, missed deadlines for responding to the regulator, or deficiencies in insurance lead to application rejection, fines, or liability for damages.

The lawyers at our Prague-based ARROWS law firm deal with this issue daily and know the CTR and the Act on Pharmaceuticals in detail.

If you do not want to risk mistakes, fines, or delays in bringing a medicinal product to market, entrust the legal supervision of your study to experts. ARROWS law firm will help you from the very first step – from reviewing contracts and the protocol to closing the study and archiving. Just write to us at consultation@arws.cz and we will arrange a consultation.

FAQ – Most common legal questions about conducting a clinical study in the Czech Republic

1. Must the sponsor be a legal entity?

The sponsor can be a natural or a legal person. However, in the vast majority of cases, it is a legal entity (pharmaceutical company, university). If the sponsor is not established in the EU, they must appoint a so-called Legal Representative in the EU, who is responsible for compliance with the regulation.

2. When do I get the study number?

You will automatically receive the 'EU CT Number' when you create the first draft of the application in the CTIS system. This number will accompany the study throughout its entire lifecycle.

3. What is the fine for not reporting an adverse event?

For breaching pharmacovigilance obligations and failing to report serious adverse events, a legal entity faces a fine of up to CZK 20,000,000 under the Act on Pharmaceuticals.

4. How long must I keep the documentation from a clinical study?

According to Article 58 of Regulation (EU) No 536/2014, the sponsor and the investigator are obliged to archive the content of the trial master file (TMF) for at least 25 years after the end of the clinical trial.

5. Do I have to report all adverse events to the SÚKL?

The sponsor reports only so-called SUSARs (Suspected Unexpected Serious Adverse Reactions) to the EudraVigilance database without delay. Other adverse events and reactions are recorded by the investigator in the documentation, and the sponsor evaluates them in the Annual Safety Reports (ASRs), which are submitted via CTIS.

6. If the application is rejected, can I file an appeal?

Yes, an appeal (in the case of a SÚKL decision, a 'rozklad') can be filed against the decision to refuse authorisation of a clinical trial. The deadline for filing is 15 days from the delivery of the decision. The lawyers at ARROWS law firm can help with the preparation of the appeal – however, precise legal and factual argumentation is key.

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About the author

Mgr. Dita Zbožínková, LL.M.
Mgr. Dita Zbožínková, LL.M.

Associate

Dita Zbožínková is an attorney at ARROWS, specializing primarily in healthcare law. She provides comprehensive legal support to her clients—primarily doctors, healthcare facilities, and outpatient providers—in all phases of their activities.

Disclaimer:

The information contained in this article is for general informational purposes only and serves as a basic guide to the issue as of 2026. Although we strive for maximum accuracy, laws and their interpretation evolve over time. We are ARROWS Law Firm, a member of the Czech Bar Association (our supervisory authority), and for the maximum security of our clients, we are insured for professional liability with a limit of CZK 350,000,000. To verify the current wording of the regulations and their application to your specific situation, it is necessary to contact ARROWS Law Firm directly (consultation@arws.cz). We are not liable for any damages arising from the independent use of the information in this article without prior individual legal consultation.