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Pharmacovigilance Regulatory Writing

PSUR, PBRER and DSUR Writing for Sponsors and Licence Holders

Pubrica writes periodic safety reports, including PBRERs, PSURs and DSURs, for clinical trial sponsors and marketing authorisation holders. Our pharmacovigilance writers prepare these reports to ICH E2C(R2) and E2F, scheduled back from the data lock point so that each report meets its submission date. Each report includes a benefit-risk evaluation that compares the position at the start and end of the interval, and is reconciled with the risk management plan and the labelling.

  • Scheduled back from the data lock point, rather than forward from the date of the request, so that reports are not submitted late
  • Current PBRER format. ICH E2C(R2) replaced the older periodic safety update report format, and we write to the current structure
  • An evaluated benefit-risk section, comparing the position at the end of the interval with the position at the start
  • Signals tracked across intervals, so that each report follows on from the previous one in the series
  • Consistent with the RMP and the labelling, because these documents are read together and any divergence will be questioned
Scope of Aggregate Safety Report Writing What is included and what is excluded

PBRER and PSURIncluded

DSURIncluded

Benefit-risk evaluation sectionIncluded

Line listings and summary tabulationsFrom your safety database

Signal detection as the accountable processYour PV function

Data lock point → assembled → evaluated → drafted → submitted

Included in every aggregate report
  • Planned from the data lock point
  • Current ICH format
  • Benefit-risk evaluated
  • Signals tracked across intervals
  • Reconciled with RMP and labelling
Quoted per reportBased on product, interval and case volume
Available on a standing cycleFor recurring reporting deadlines
ICH E2C(R2) and E2FPBRER and DSUR formats
ISO 9001:2015Quality management certified · cert. H3CR9TCU20251212INDQM10N

Deliverables

PSUR, PBRER and DSUR Deliverables

Each report covers one product, one interval and one data lock point, and its content is limited to what the safety database holds at lock.

A Schedule Planned Back From the Data Lock Point The data lock point, database extraction, drafting window, review cycles and submission date are planned as one sequence at the start of the project.

Example from a project planPeriodic reports are most often late because the schedule is built forward from the request date rather than back from the submission date. The data lock point is fixed.

The Current ICH Format ICH E2C(R2) introduced the periodic benefit-risk evaluation report, which is structured around evaluation rather than around tabulation.

Example from a format checkSection: summary of safety data received during the interval.Evaluation of signals and risk information, characterisation of risks, benefit evaluation and integrated benefit-risk analysis. The tabulations are inputs to the evaluation.

An Evaluated Benefit-Risk Section The section compares the position at the end of the interval with the position at the start and explains what changed and what it means, rather than restating the approved indication.

Example from a benefit-risk evaluationThe benefit-risk balance for the product remains positive.Two new signals evaluated during the interval, one closed as refuted and one added to the RMP as an important potential risk with a characterisation study. The balance remains positive; the basis for that statement has changed and the report says how.

Continuity Across the Report Series Signals, commitments and open actions are tracked from one interval to the next, so a reviewer reading consecutive reports can follow each issue.

Example from a series handoverA report that does not refer to what the previous report said about an open signal will raise questions from reviewers.

The samples shown are illustrative and anonymised. Hover over a sample to replay it.

Compliance and Standards

Periodic Safety Report Guidelines and Quality Standards

Where your agency or your safety function has a stated position, we follow it.

ICHE2C(R2)

Periodic benefit-risk evaluation report (replaced the old PSUR format)

The current periodic report structure, organised around evaluation of the benefit-risk position rather than tabulation of cases.

ICHE2F

Development safety update report (for products in development)

The annual development-phase report, which covers what was learned about safety during the reporting period and its implications for ongoing trials.

GVPModule VII

Good pharmacovigilance practices (periodic safety reports)

Sets the EU expectations on scope, timing, format and the relationship between the periodic report and the risk management plan.

ISO9001:2015

Quality management (cert. H3CR9TCU20251212INDQM10N)

Our quality management system governs how each document is drafted, reviewed, version-controlled and released.

Responsible Use of AI

Responsible Use of AI in Regulatory Writing

Regulatory reviewers trace each decision back to its evidence and to a named individual. For this reason, source traceability takes priority over speed in our regulatory writing, and every statement must be traceable to its source.

How We Use AI ToolsWe use AI tools to locate source material across a document set, to check the consistency of terms, figures and cross-references between documents in a submission, and to draft highly templated sections that a writer then verifies line by line against the source.
Where We Do Not Use AIWe do not use AI tools for text that enters a submission as drafted, for clinical or benefit-risk interpretation, safety narratives or literature appraisal for a clinical evaluation, or for any statement an assessor would expect to trace to a named, qualified individual.
What Your AI Declaration Should IncludeYour declaration should name the tool, the stage at which it was used and the human oversight applied. Journals, funders, regulators and the ICMJE January 2026 update now expect this, and an undeclared tool found later is treated as an integrity matter.

Why We Do Not Publish an AI Accuracy Figure

Accuracy figures for AI tools are usually reported by the companies that sell them.

Pubrica therefore does not quote a self-generated accuracy figure, because it would carry the same conflict of interest. Instead, we tell you which tool was used on your project, at which stage, and what a specialist changed afterwards.

Methodology

How Our Periodic Safety Report Writing Process Works

We build the schedule back from the data lock point, and every later step follows from it.

Step one

Scheduling From the Data Lock Point

We map the lock point, extraction, drafting, review cycles and submission as one sequence and identify the critical path.

Step two

Data Assembly

We assemble and reconcile line listings, summary tabulations, exposure estimates and literature from your safety database and other sources.

Step three

Evaluation and Drafting

We evaluate signals and risk information, characterise the risks and write the integrated benefit-risk analysis as an evaluation.

Step four

Reconciliation and Submission Support

We check the report against the RMP and the labelling, consolidate review comments and deliver the report for your submission.

Our Experts

Our Periodic Safety Report Writing Team

A named team of regulatory specialists stays with your project from scoping to delivery. Your project coordinator introduces each team member by name before work begins.

Regulatory medical writerAuthors the document to the applicable template and guidance

Writes the document against the governing template and regulatory guidance, keeps every statement traceable to its source data, and maintains the version history and comment log through each review round.

Responsible forDrafting and source traceability
Reviews againstICH, EU MDR/IVDR or FDA guidance, as applicable
OutputSubmission-ready document
Subject matter expertClinical or scientific expert matched to your product area

Reviews the clinical and scientific content for accuracy and confirms that each conclusion is supported by the data. Each expert is matched to your therapeutic or device area.

Responsible forScientific accuracy and interpretation
Reviews againstSource data and the current literature
FieldMatched to your product
BiostatisticianStatistical review where the document reports analysed data

Checks that statistical methods, tables and conclusions are consistent with the analysis plan, and reviews how the data are presented before the document reaches regulatory review.

Responsible forStatistical accuracy
Reviews againstICH E9 and the statistical analysis plan
ToolsR, SAS, Stata
Regulatory QC reviewerIndependent quality check before delivery

Performs an independent check of the final document against source data, the template and the applicable regulatory checklist. Findings are logged and resolved before delivery.

Responsible forIndependent quality control
Reviews againstSource data and regulatory checklists
Signed off byProject lead

Packages

PSUR, PBRER and DSUR Service Packages

Pricing depends on the product, interval length, case volume and whether there is an existing series to continue.

Report

Single report

One PBRER, PSUR or DSUR

Quoted per projectBased on product, interval and case volume

Delivery Delivered to the submission deadline

  • ✓Schedule worked back from the data lock point
  • ✓Data assembled and reconciled
  • ✓Signals and risk information evaluated
  • ✓Integrated benefit-risk analysis
  • ✓Reconciled with RMP and labelling
  • ✓Two review cycles

We recommend commissioning at least one interval ahead, because the data lock point is fixed.

Deliverables Request a quote
Series

Standing arrangement

Products with recurring reporting obligations

Quoted per projectBased on portfolio and reporting frequency

Delivery By schedule

  • ✓Reports produced on the recurring cycle
  • ✓Signals and commitments tracked across intervals
  • ✓Continuity of authorship and terminology
  • ✓RMP updates aligned to the reporting cycle
  • ✓A standing schedule rather than a series of requests

Aggregate reporting is recurring and deadline-driven, so a standing arrangement is usually more efficient than individual requests.

Deliverables Request a quote

Send the last report in the series and the next data lock point, and we will prepare a schedule at no cost, including the critical path, which is usually the data extraction rather than the drafting.

FAQs

PSUR, PBRER and DSUR FAQs

If your question is not answered here, ask an expert. No quote is required.

Not exactly. ICH E2C(R2) introduced the periodic benefit-risk evaluation report, which replaced the older periodic safety update report format and is organised around evaluation rather than tabulation.

Many organisations still use the term PSUR informally, and some regional requirements still use it. A template that refers only to a PSUR may follow the older structure and is worth checking.

At least one interval ahead. The data lock point is fixed, and extraction, reconciliation, drafting and review must all fit between it and the submission date.

When the schedule is built back from the data lock point, the critical path is usually the data extraction rather than the writing.

It must evaluate the data. A section that restates the approved indication and concludes that the balance remains positive has not evaluated anything.

An effective evaluation compares the position at the end of the interval with the position at the start, states what changed and explains whether the conclusion still holds.

No. Case intake, coding, the safety database and signal detection as the accountable process sit with your pharmacovigilance function or provider.

We write the report from the data held in that system and reconcile the report against it. This separation of roles is deliberate.

Related Services

Related Pharmacovigilance and Regulatory Writing Services

Periodic safety reports are read alongside the risk management plan and the labelling.

Request a Free Reporting Schedule Based on Your Data Lock Point

We will prepare a schedule at no cost, including the critical path, which is usually the data extraction rather than the drafting.

Get a free quote

Regulations

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