Regulatory Expectations and How Programs Meet Them
Regulatory agencies expect a clearly defined ADA and NAb strategy supported by fit-for-purpose assays and full validation of sensitivity, selectivity, drug tolerance, and MRD justification. Submissions must include ADA incidence summaries linked to PK, PD, efficacy, and safety using validated analytical and clinical datasets.
For development teams, inadequate ADA or NAb strategies undermine confidence in PK, efficacy, and dose justification, increasing the likelihood of program delays, additional studies, or clinical attrition.
In 2025, the FDA reported that many Complete Response Letters (CRLs) were driven by analytical and CMC deficiencies that undermined the reliability of immunogenicity and bioanalytical data.
Neutralizing antibody assay expectations
Regulatory agencies, including the European Medicines Agency, state that cell-based neutralizing antibody assays are the preferred approach, as they directly measure biological function and pathway inhibition.
Ligand-binding neutralizing antibody assays are considered acceptable only in limited cases, when all of the following conditions are met:
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The mechanism of action is well understood
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Neutralization occurs solely through blocking a defined binding interaction
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A relevant and robust cell-based assay is not feasible
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The ligand-binding format can be scientifically justified as reflective of in vivo function
In practice:
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Monoclonal antibodies, cytokines, and growth factors typically require cell-based assays
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Simple receptor–ligand blockade mechanisms may allow ligand-binding formats
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Complex mechanisms or downstream signaling pathways require cell-based assays
Takeaway: Cell-based assays are the default regulatory expectation. Ligand-binding approaches require clear scientific justification.
Role of CMC in immunogenicity risk
CMC attributes have a strong influence on immunogenicity risk. Aggregation, charge variants, oxidation, glycan drift, sequence variants, excipient instability, and residual impurities can all increase the likelihood or magnitude of ADA responses.
Together, these data show that immunogenicity cannot be evaluated in isolation. CMC attributes shape the structure and stability of the therapeutic, which in turn shapes ADA risk. Strong CMC control supports meaningful ADA and NAb interpretation and reduces the risk of regulatory delays.