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How do life sciences companies build an IT landscape that is GxP-compliant, validated and at the same time fast enough for the business?

We support pharma, biotech, MedTech and IVD companies in selecting, implementing and operating GxP-relevant IT systems in a validated state: from technology assessment through computerized system validation under GAMP 5 to safeguarding data integrity and audit trails. The crucial point is rarely the technology, it is the sequence: companies that examine validatability, data integrity and supplier qualification only after the system has been selected accumulate technical debt that makes every inspection expensive later on.

Overview

What requirements does the regulatory framework place on IT systems in life sciences?

GxP IT across pharma, biotech, MedTech & IVD · GAMP 5, 21 CFR Part 11, EU GMP Guide Annex 11, AI Act (EU) 2024/1689

Last updated: June 13, 2026

As soon as an IT system creates, processes or stores GxP-relevant data, it becomes a regulated object in its own right. Selection, implementation and operation must meet the requirements for validation and data integrity, otherwise the system becomes a weak point in the audit instead of a lever for efficiency. The points at which IT projects in regulated environments most often get stuck:

  • Validatability as a selection criterion: A GxP-relevant system must be validatable on a risk-based approach under GAMP 5. Audit trail capability, access controls and available supplier validation documentation are decided before the purchase, not at go-live.
  • Data integrity to ALCOA+: Electronic records must be attributable, legible, contemporaneous, original and accurate, complemented by complete, consistent, enduring and available. 21 CFR Part 11 and the EU GMP Guide Annex 11 require tamper-evident audit trails and unambiguous user authentication.
  • Supplier and cloud responsibility: For SaaS and cloud hosting of GxP-relevant data, regulatory responsibility remains with the regulated company. The provider must be assessed against 21 CFR Part 11, Annex 11 and EU GMP Guide Chapter 4.
  • AI in regulated operation: Data-driven and AI-supported applications are additionally subject to the AI Act (EU) 2024/1689, whose obligations are calibrated to the risk of the application. Data with a personal reference falls in parallel under the GDPR (EU) 2016/679.

Services

How we support you

Technology strategy & system selection

As-is analysis of the existing IT landscape, requirements catalog and structured selection process with a regulatory pre-assessment of validatability. Deliverable: an assessed technology roadmap prioritized by business value and GxP risk.

GxP IT supplier & cloud assessment

Vendor assessment of software suppliers and cloud providers against 21 CFR Part 11, Annex 11 and EU GMP Guide Chapter 4. Deliverable: a supplier audit report with an assessment of the outsourced electronic records.

Implementation & integration support

Project management or support for IT implementations, including requirements engineering, interface design and coordination with the validation activities. Deliverable: an implementation plan with an integrated validation and data migration concept.

What it comes down to

In regulated environments, it is not the breadth of a system's functionality that decides project success, but the sequence of the checks. Three strands must come together before a system goes into production: validatability under GAMP 5, data integrity to ALCOA+ with a tamper-evident audit trail against 21 CFR Part 11 and the EU GMP Guide Annex 11, and supplier responsibility for outsourced records. Companies that examine these strands only after the selection decision lose the weakest one as a bottleneck, usually the validatability of a system that has already been purchased. That is precisely why the regulatory pre-assessment belongs at the start of the selection process and not at the end of the implementation.

The second lever is the data architecture across system boundaries. Every uncontrolled transfer between silos that have grown over time is a potential data integrity breach, which Annex 11 requires to be a controlled, traceable process. Once data-driven or AI-supported applications are added, the AI Act (EU) 2024/1689 adds a risk-based layer of obligations, and where there is a personal reference the GDPR (EU) 2016/679 applies in parallel. We therefore start early: first assess the GxP relevance and the risk of each application, then anchor validation, audit trail review and data protection so that the effort shifts to the front, where corrections are cheap, rather than into the inspection, where they delay the project.

Our approach

Our approach

01

As-is analysis & requirements

Documented IT landscape, GxP relevance assessed per system, prioritized requirements catalog.

02

System selection & pre-assessment

Assessed options with supplier qualification and a pre-assessment of validatability under GAMP 5.

03

Implementation & integration

Configured system with defined interfaces, access concept and data migration plan.

04

Validation & data integrity

Validation documentation under GAMP 5, activated audit trails and ALCOA+ compliant records.

05

Go-live & audit trail review

Productive operation with a documented audit trail review routine and supplier governance.

Common pitfalls

Where projects commonly fail

Validatability is examined only after the system has been selected.

If a system is purchased without sufficient audit trail capability or without available supplier validation documentation, it can be validated under GAMP 5 only with considerable additional effort, or it lacks GxP suitability altogether.

The audit trail exists but is switched off or is never reviewed.

An audit trail that is available at the system level but deactivated or never reviewed satisfies neither 21 CFR Part 11 nor Annex 11. Without a documented review routine, the gap remains undetected until inspection.

GxP data moves to the cloud without a supplier assessment.

Data is hosted on SaaS or cloud infrastructure without the provider having been assessed against 21 CFR Part 11, Annex 11 and EU GMP Guide Chapter 4. Responsibility for the outsourced records remains with the regulated company.

AI applications go into operation without regulatory classification.

A data-driven application is put into productive use before its obligations under the AI Act (EU) 2024/1689 have been clarified and before any personal reference has been checked against the GDPR. Traceability and validation scope are difficult to establish after the fact.

Systems that have grown over time remain unintegrated.

Without an overarching architecture, silos arise with duplicate data entry and media breaks. Every uncontrolled data transfer between systems is a potential data integrity breach, which Annex 11 requires to be a controlled, traceable process.

Supply Chain & Technical Operations

Do any of these pitfalls apply to you?

In a first call we assess your situation and say what needs clarifying first in your case. Without obligation, reply usually within one working day.

FAQ

Frequently asked questions

As soon as a system creates, processes or stores data that affects GxP decisions or product quality, it is GxP-relevant and must be validated on a risk-based approach under GAMP 5. The validation scope follows the risk of the application, not the size of the system.

Sources
  • 21 CFR Part 11 (FDA) - Electronic Records; Electronic Signatures, primary text
  • EU GMP Guide Annex 11 - Computerised Systems
  • EU GMP Guide Chapter 4 - Documentation
  • GAMP 5 (ISPE) - A Risk-Based Approach to Compliant GxP Computerised Systems
  • Regulation (EU) 2024/1689 (AI Act) - primary text
  • Regulation (EU) 2016/679 (GDPR) - primary text
  • Technology Excellence source material (Entourage writer output, business-data-it)

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Regulations & standards considered

  • 21 CFR Part 11 (FDA, Electronic Records; Electronic Signatures)
  • EU GMP Guide Annex 11 (Computerised Systems)
  • EU GMP Guide Chapter 4 (Documentation)
  • GAMP 5 (ISPE, A Risk-Based Approach to Compliant GxP Computerised Systems)
  • AI Act (EU) 2024/1689
  • General Data Protection Regulation (EU) 2016/679 (GDPR)

Have a concrete project?

Briefly outline your situation. We'll respond with an initial assessment, usually within one business day.

Prefer direct? +49 89 4161170-0
info@theentourage.de

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