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Guideline for Biosimilar Drug Development in 2026

A 2026 guide to biosimilar drugs development, focusing on analytical similarity, PK evidence, and evolving FDA and EMA expectations.

Biosimilar drugs development is the process of demonstrating that a biological drug is highly similar to an already approved biologic, with no clinically meaningful differences in safety, purity, or potency.

In 2025, regulatory agencies increasingly allow reduced clinical efficacy requirements when analytical and clinical pharmacology evidence is sufficiently strong. This implies that analytical development is now the primary driver of success for biosimilar drugs.

 

 

What question will be covered:

 

  • What are biosimilar drugs, and how are they different from small-molecule generics?
  • How biosimilar drugs development in 2025 changed compared with previous regulatory expectations?
  • FDA and EMA expectations from biosimilar developers in 2026
  • When can comparative clinical efficacy studies be reduced or avoided in biosimilar programs?
  • Why analytical gaps are now key to program-level risk in biosimilar drugs development?

What are biosimilar drugs?


Biosimilar drugs are biological medicines developed to be highly similar to an already approved biologic drug, known as the reference product. Because biologics are large, structurally complex molecules produced in living systems, biosimilar drugs cannot be exact molecular copies in the way small-molecule generics are.

The scientific and regulatory goal of biosimilar drugs development is to demonstrate that any observed differences do not result in clinically meaningful differences in safety, purity, or potency.
 
Key takeaway: Biosimilar drugs are approved by proving similarity through analytical evidence, not by duplicating a molecule.

Regulatory momentum toward analytical evidence for biosimilar drugs

 

Regulators are changing how they evaluate biosimilar drugs. Both U.S. Food and Drug Administration (FDA) and European Medicines Agency (EMA) agencies clearly signal a move toward analytically driven biosimilar approval, with increasing alignment across regions.

 

In April 2025, the EMA released a draft reflection paper (for public consultation) to explore when clinical efficacy data may be de-emphasized in favor of analytical and PK evidence. The paper does not create a formal guideline with regulatory force yet, but it signals EMA’s intent.

 

Similarly, in October 2025, the FDA released a draft guidance proposes that for many biosimilars, especially well-characterized proteins, the agency may no longer routinely require comparative clinical efficacy studies (CES) if robust analytical and pharmacokinetic data sufficiently demonstrate similarity to the reference product. The draft replaces older expectations by emphasizing comparative analytical assessment (CAA) and targeted PK data, and was published to reduce time/cost burdens on biosimilar developers.

 

Additionally, in 2025, the FDA finalized a guidance on therapeutic protein biosimilars (focused on comparative analytical studies), which further clarifies current expectations for demonstrating analytical similarity.

 

 

Aspect United States (FDA) Europe (EMA)
Regulatory signal Draft guidance (Oct 2025) Draft reflection paper (Apr 2025)
Role of analytics Analytical similarity as the foundation of approval Strong analytical & PK evidence supports tailored approach
Impact on clinical studies Comparative clinical efficacy studies may be reduced Clinical requirements may be reduced under defined conditions
Interchangeability policy Guidance aims to simplify or reduce switching study requirements Not centrally addressed; substitution policies vary by member state
Objectives Streamline development, cut time and cost Improve access while maintaining safety standards
Status Feedback period concluded; guidance moving toward finalization Open public consultation until late 2025
Key takeaway Analytical similarity is central to biosimilar approval EMA is moving toward analytically led biosimilar development

 

 

Interchangeability is a regulatory designation used in the United States that applies to certain biosimilar drugs.

If a biosimilar is designated as interchangeable by the FDA:

  • A pharmacist may substitute it for the reference biologic without contacting the prescriber, depending on state law

  • The patient should expect the same clinical outcome, even if switched back and forth

 

 

A clear trend toward regulatory harmonization


Global regulators are converging on analytical excellence as the basis for reducing clinical study requirements for biosimilar drugs. When analytical characterization is deep, orthogonal, and scientifically rigorous, the need for large comparative clinical trials can be significantly reduced without compromising regulatory confidence.

What this means for biosimilar drugs developers

 

FDA and EMA evidence requirements for biosimilar drug development in 2026 now depends primarily on analytical strength rather than clinical scale. Consequently, developers must invest early in analytical strategies capable of detecting and justifying subtle structural and functional differences. Analytical gaps that were previously compensated by clinical data now represent program-level risk, often leading to delayed timelines, additional regulatory questions, or the need for late-stage study redesigns.

 

FDA-EMA-requirements-biosimilar-drug-development-2026

Why biosimilar drugs development is becoming an analytical challenge in 2026


In 2025, biosimilar drugs development has shifted toward an analytically driven regulatory model. Instead of relying heavily on large clinical efficacy studies, they are placing more weight on strong analytical and pharmacokinetic evidence.. The consequences are that in 2026 scientific risk in biosimilar drugs programs has moved upstream into analytical development.

 

Read more: The 6 Most Common Analytical Gaps in Biosimilar Programs (and how to fix them)

How biosimilar drugs development works

 

This model applies to therapeutic protein biosimilar drugs intended for regulated markets such as the United States and Europe

 

Step 1. Reference product analysis

Extensive characterization of the approved reference biologic is performed to establish a detailed quality target profile.

 

Step 2. Analytical similarity assessment

High-resolution analytical methods compare the biosimilar drug and reference product across critical quality attributes, including:

 

  • Primary and higher-order structure
  • Post-translational modifications
  • Charge and size variants
  • Biological and functional activity


Step 3. Nonclinical and functional studies

Targeted in vitro and, when required, in vivo studies confirm that observed analytical differences do not affect biological function.

 

Step 4. Clinical pharmacology

Pharmacokinetic and pharmacodynamic studies compare in vivo behavior between the biosimilar drug and the reference product and are often the primary clinical requirement.

 

Step 5. Limited clinical confirmation when required

Depending on molecule complexity and analytical strength, regulators may require reduced or no comparative clinical efficacy studies.


Key takeaway: Modern biosimilar drugs programs are built analytically first, clinically second.

Biosimilar drugs FAQs


Do all biosimilar drugs still require comparative clinical efficacy studies?

Not always. For many well-characterized biologics, regulators may accept reduced or no comparative clinical efficacy studies when analytical and clinical pharmacology data are sufficiently strong.

 

What role does clinical pharmacology play in biosimilar drugs development?

Clinical pharmacology studies, particularly pharmacokinetics and pharmacodynamics, are often the primary clinical requirement and help confirm in vivo similarity.

 

Why is analytical similarity more important for biosimilar drugs than before?

Advances in analytical technologies allow detection of subtle structural and functional differences, reducing uncertainty and reliance on large clinical trials.

 

Are biosimilar drugs developed faster than originator biologics?

Yes. Biosimilar drugs development is generally faster and more cost-efficient, provided analytical programs are robust and well designed.

 

Does this approach apply to all biologic modalities?

No. The extent of clinical reduction depends on molecule complexity, mechanism of action, and the strength of analytical characterization.

 

When should developers engage analytical experts for biosimilar drugs?

Analytical strategy should be defined early, ideally before major development decisions are locked in.

 

 

 

 

 

Reviewed by Crystal Bio Solutions scientific team. January, 2026.

Case Study: A Generic LC-MS/MS Solution for ADC PK Bioanalysis