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EU GMP Annex 11

Annex 11, rewritten: what the draft asks of every computerised system

The 2011 annex fitted on four pages. The 2025 consultation draft runs to roughly nineteen, and most of the new text turns expectations that inspectors already held into written requirements.

Kestrel Life SciencesOctober 20268 min readStatus at 9 October 2026: Draft. Consultation closed 7 October 2025; the 2011 text remains in force.

For fifteen years EU GMP Annex 11 has been short enough to read over a coffee. That brevity was a strength when it was written and a weakness ever since: inspectors filled the gaps with Q&As, data integrity guidance and their own experience, and companies filled them with interpretation. The draft revision published for consultation on 7 July 2025, alongside a revised Chapter 4 on documentation and a new Annex 22 on artificial intelligence, closes most of those gaps in writing.

From a short annex to a full rulebook Approximate length, EU GMP Annex 11 2011 (in force)≈ 4 pages 2025 draft≈ 19 pages TOPICS THAT NOW HAVE THEIR OWN REQUIREMENTS Risk managementRequirementsSupplier and cloud servicesAlarmsIdentity and access managementAudit trailsElectronic signaturesPeriodic reviewSecurityBackup and restoreArchivingConfiguration management Largest change from 2011 practice Previously implied, guidance or Q&A; now written down
Figure 1. Length and new dedicated topics in the 2025 consultation draft compared with the 2011 annex. Page counts are approximate.

What actually changes

Very little in the draft will surprise anyone who has hosted a recent inspection. What changes is that the expectations become auditable line by line. The headline shifts are these.

Validation becomes a lifecycle, not an event

The draft is explicit that a computerised system is validated before use and kept in a validated state for its whole life, through to a documented decommissioning. The project-shaped validation package that is filed and forgotten at go-live no longer meets the text.

Audit trails stop being a risk-based option

The 2011 annex asked companies to consider building in an audit trail based on a risk assessment. The draft expects audit trails to be there and to be reviewed: targeted, timely, and normally completed before the batch is released, by people who were not directly involved in the work. We cover how to make that review useful in a separate article.

Access control gets specific

Named accounts, least privilege, segregation of duties, recurring access reviews and multi-factor authentication for remote access to critical systems from outside the controlled network. None of this is new practice; all of it is now a requirement you can be cited against. See our article on identity and access.

Alarms get their own section

Alarms are recorded, acknowledged with a justification and periodically reviewed. For anyone running process control, building management or environmental monitoring, this pulls alarm management squarely into the computerised system's validated state.

Security is no longer four paragraphs

Patching, firewalls, penetration testing and disaster recovery all appear in the security section. The practical consequence is that IT security evidence becomes GMP evidence, and the security team becomes part of the validation conversation.

Suppliers and the cloud are in scope by name

The draft treats service providers, including cloud and software-as-a-service providers, as part of how a regulated company meets its obligations. Contracts, oversight and the evidence a provider supplies all need to stand up. Our cloud article sets out what that means in practice.

Periodic review becomes a programme

Instead of a line saying systems should be periodically evaluated, the draft defines what a review covers and expects its frequency to be justified by risk. Changes, incidents, deviations, access, audit trail findings and the system's continued fitness for purpose all belong in it.

Kestrel view

The draft does not invent a new discipline. It writes down the one good companies already practise, and removes the room for argument about whether it was ever required.

Timing: what is binding today

The consultation closed on 7 October 2025. At the time of writing the European Commission has not published a final text, and EudraLex Volume 4 still carries the 2011 Annex 11 and Chapter 4. Industry commentary expects the drafting group to hand a final text to the Commission towards the end of 2026, followed by a transition period before it applies. Until then the 2011 annex is the legal text, but inspectors are already reading it through the lens of the draft.

Read across to the United States. 21 CFR Part 11 has not been amended, but FDA's direction of travel, through Computer Software Assurance and its AI credibility framework, points the same way: effort proportionate to risk, and evidence that controls work in use. See Part 11 and AI.

Five things to do before the final text lands

  1. Run a gap assessment of your system inventory against the draft, starting with the systems that support batch release.
  2. Write, or rewrite, the audit trail review procedure so that it names what is reviewed, by whom and when.
  3. Check remote access to critical systems for multi-factor authentication, and close the exceptions.
  4. Pull your SaaS and cloud contracts and compare them with the draft's expectations of service providers.
  5. Turn periodic review into a scheduled programme with risk-justified frequencies and a defined scope.

Sources and further reading

Regulatory status is stated as at 9 October 2026. Draft texts can change before they are finalised; always work from the current published version.

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