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Pharmacovigilance

Periodic Safety Update Report(PSUR)

Periodic Safety Update Report is a pharmacovigilance document a marketing authorisation holder submits at fixed intervals to re-evaluate an authorised medicine's benefit-risk balance against the safety data accumulated worldwide since the previous report.

Usage Examples

  • The EURD list moved our data lock point, so the PSUR is now due 70 days from 30 September, not from the approval anniversary.
  • That signal was closed in the last PSUR, so this interval needs a benefit-risk restatement rather than a fresh evaluation.
  • We file a PSUR in the EU and a 314.80(c)(2) periodic report in the US off the same safety database, but the two have different scopes.

What is Periodic Safety Update Report (PSUR)?

Periodic Safety Update Report is a pharmacovigilance document a marketing authorisation holder submits at fixed intervals to re-evaluate an authorised medicine's benefit-risk balance against the safety data accumulated worldwide since the previous report.

Periodic Safety Update Reports exist because a marketing authorisation is granted on trial data from a controlled population, while the safety profile that matters emerges later, in routine use, across markets the sponsor does not directly observe. PSURs force the marketing authorisation holder to stop at fixed points, aggregate what was learned worldwide in that window, and state in writing whether the benefit-risk balance still holds.

Periodic Safety Update Reports cover the cumulative and interval safety experience of an authorised medicine: exposure estimates, signals evaluated during the period, and the benefit-risk conclusion that follows. PSURs do not replace expedited reporting, so individual serious reactions still go in on their own clock. PSURs also stop at the authorisation boundary: safety data on a product still in clinical development belongs in a development safety report, not here.

Periodic Safety Update Reports run on an externally fixed calendar rather than the author's schedule. The EU reference dates list sets each active substance's data lock point and reporting interval and is legally binding, and the submission clock then runs 70 or 90 calendar days from that data lock point. PSURs are required for both centrally and nationally authorised medicines, whichever assessment route the product follows.

Not to be confused with

PBRER
PBRER is the ICH E2C(R2) report format; PSUR is the EU legal obligation discharged using that format. One is a template, the other is a filing duty with a statutory deadline attached.
ICSR
an ICSR reports a single case on an expedited clock. A PSUR aggregates and interprets a whole interval, and submitting PSURs on time discharges none of the expedited case-reporting obligation.
DSUR
a DSUR reports the safety of a product under clinical development; a PSUR reports the safety of a product already authorised. A sponsor with a marketed product still in development files both, from the same database, on different clocks.
21 CFR 314.80(c)(2) periodic report
the US periodic adverse drug experience report is not a PSUR. Periodic reporting under 314.80(c)(2) excludes adverse experiences obtained from postmarketing studies, so its scope is narrower than the worldwide view an EU PSUR demands.

The obligations split by jurisdiction; these are the anchors a PSUR programme is audited against.

What you must do

  1. 1Compile every PSUR to the format and content prescribed by EU law, which has been legally binding since January 2013Commission Implementing Regulation (EU) No 520/2012
  2. 2Take the reporting interval and data lock point from the EU reference dates list rather than from the product's approval date, and treat that list as binding on the marketing authorisation holderEU reference dates (EURD) list
  3. 3Submit within 70 calendar days of the data lock point for intervals up to 12 months, and within 90 calendar days for intervals longer than 12 monthsGVP Module VII
  4. 4For US applications, file periodic adverse drug experience reports at quarterly intervals for 3 years from approval and annually thereafter, with quarterly reports within 30 days of the close of the quarter and annual reports within 60 days of the anniversary date21 CFR 314.80(c)(2)
  5. 5Keep adverse experiences obtained from postmarketing studies, the scientific literature, and foreign marketing experience out of the US periodic report, except for information regarding 15-day Alert reports21 CFR 314.80(c)(2)

Common mistakes

  • Writing the PSUR as a case listing instead of an assessment

    EU law fixes the content, so an absent interval signal evaluation or an unstated benefit-risk conclusion is a deficiency, not a stylistic choice. It draws assessment questions, extends the procedure, and puts the burden of proving the balance back on the holder mid-review.

  • Anchoring the schedule to the approval date instead of the EURD list

    The EU reference dates list, not the marketing authorisation date, sets the data lock point and the interval, and it is legally binding. Teams working from an internal anniversary calendar discover the mismatch after day 0 has already passed, with only part of the 70-day window left.

  • Filing EU PSUR content as the US periodic report

    Periodic reporting under 21 CFR 314.80(c)(2) does not extend to adverse experiences from postmarketing studies, the scientific literature, or foreign marketing experience, except for 15-day Alert report information. Copying the PSUR across submits a document that answers a different question and buries the analysis the US regulation actually requires.

When This Matters

  • The EURD list moved our data lock point, so the PSUR is now due 70 days from 30 September, not from the approval anniversary.
  • That signal was closed in the last PSUR, so this interval needs a benefit-risk restatement rather than a fresh evaluation.
  • We file a PSUR in the EU and a 314.80(c)(2) periodic report in the US off the same safety database, but the two have different scopes.

Frequently Asked Questions

PBRER is the ICH E2C(R2) report format; PSUR is the EU legal obligation that has to be discharged using that format. In the EU the two names describe the same deliverable, because Commission Implementing Regulation (EU) No 520/2012 fixed PSUR format and content on the ICH E2C(R2) structure.

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