ARCHIVED Guidance on applications for drug clinical trials under the interim order: Overview

Notice to Reader:

We have replaced the Interim Order No. 2 respecting clinical trials for medical devices and drugs relating to COVID-19. See the regulations notice about the Clinical Trials for Medical Devices and Drugs Relating to COVID-19 Regulations.

Published: May 27, 2020

Updated: May 3, 2021

This guidance document supports the Interim Order No. 2 Respecting Clinical Trials for Medical Devices and Drugs Relating to COVID-19 (IO No. 2), which was made pursuant to subsection 30.1(1) of the Food and Drugs Act. IO No. 2 was signed by the Minister on May 3, 2021, which replaced the first interim order (IO No. 1).

The document provides guidance to:

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Scope and application

Applicants of COVID-19 drug clinical trials may apply for authorization under IO No. 2 or under Part C, Division 5 of the Food and Drug Regulations. Those authorized under IO No. 2 would be exempt from Division 5 and other provisions of the Regulations, except where described in the IO and subject to certain modified requirements. These include the following:

IO No. 2 also ensures that all existing authorizations, suspensions and exemptions for clinical trials issued under IO No. 1, including any terms and conditions, will remain in effect. As well, any applications that were outstanding when IO No. 1 expired would be deemed to be applications made under IO No. 2.

As was the case under IO No. 1, trials already under way (filed under Part C, Division 5) or new trials filed under Part C, Division 5 and not authorized under IO No. 1, cannot be transitioned to this interim order. Authorization holders continue to hold their existing authorizations under the regulatory framework for which they were approved.

IO No. 2 applies to COVID-19 drug and medical device clinical trials, which are expected to be the predominant therapies related to COVID-19. For guidance on COVID-19 trials using medical devices, please see the guidance document Applications for medical device clinical trials under the interim order.

COVID-19 drugs include pharmaceutical drugs and biologic drugs (including vaccines, blood and blood components) that are the subject of a clinical trial. Radiopharmaceuticals (see Schedule C of the Food and Drugs Act) and natural health products are not covered in the interim order. Division 5 of the Regulations and associated guidance continue to apply for all non-COVID-19-related clinical trials and those that are not covered in the interim order.

Policy objectives

IO No. 2 continues to facilitate clinical trials to investigate and offer Canadians potential drugs that may diagnose, treat, mitigate or prevent COVID-19. It also continues to uphold strong participant safety precautions and validity of trial results.

Policy statements

Health Canada is committed to continue prioritizing the review of clinical trial applications that investigate the diagnosis, treatment, mitigation or prevention of COVID-19.

IO No. 2 enables efficiencies to help further facilitate the conduct of COVID-19 clinical trials for both new drugs and repurposed marketed drugs.

Clinical trial authorization holders must conduct COVID-19 clinical trials according to high ethical research standards and ensure the safety of participants.

As such, many requirements from Division 5 of the Regulations that protect trial participants and those who help ensure the reliability of results are duplicated in IO No. 2.

To facilitate use of this pathway, existing guidance is referenced and the process for submitting applications, amending and providing additional information is maintained.

Where possible and where proper procedures are in place to monitor such activities remotely from the site, clinical trial activities may include virtual recruitment, informed consent, monitoring and/or visits.

For additional considerations when conducting a COVID-19 clinical trial, please refer to the Management of clinical trials during the COVID-19 pandemic: Notice to clinical trial sponsors.

COVID-19 drug clinical trials authorized under this interim order are subject to compliance and enforcement measures.


COVID-19 is the infectious disease caused by the recently discovered coronavirus, SARS-CoV-2. This new virus and disease were unknown before the outbreak began in December 2019 and have since spread around the world. COVID-19 has been known to cause respiratory symptoms, fever, cough, shortness of breath and breathing difficulties. In more severe cases, COVID-19 infection can cause pneumonia, severe acute respiratory distress, kidney failure and death. Older people and those with underlying medical problems, such as high blood pressure, heart problems or diabetes, are more likely to develop serious illness.

The World Health Organization declared a global pandemic related to COVID-19 on March 11, 2020. Originally seen to be a local outbreak, it has now affected most countries across the globe. The situation continues to evolve and change. As there are a limited number of authorized therapies and vaccines to effectively treat or prevent COVID-19, there continues to be an urgent need to get such therapeutic products into clinical trials. Clinical trials are an important step in finding safe and effective treatment options for patients.

IO No. 2 and this guidance document have been developed to ensure that drugs for diagnosing, treating, mitigating or preventing COVID-19 can be investigated efficiently within a clinical trial.


Unless explicitly listed below or in IO No. 2, all phrases in the interim order have the same meaning as those in Division 5 of the Regulations. For a full list of applicable definitions, see section 2.1 of the Guidance document for clinical trial sponsors: Clinical trial applications.

Applicant/ authorization holder
Has the same meaning as sponsor in Division 5 (an individual, corporate body, institution or organization that conducts a clinical trial) and is the person applying or authorized to conduct the clinical trial.
Clinical trial
A study involving human subjects (participants) for the purpose of discovering or verifying the effects of a drug, a device or a food for a special dietary purpose.
Clinical trial site
The location where a qualified investigator conducts or monitors clinical trial activities.
The coronavirus disease 2019 (COVID-19).
COVID-19 drug
A drug for human use that is manufactured, sold or represented for use in relation to COVID-19.
COVID-19 drug authorization
An authorization to:
  • import or sell a COVID-19 drug that is to be tested in a clinical trial
  • conduct a clinical trial in respect of such a drug
Interim Order No. 1 (IO No. 1)
The Interim Order Respecting Clinical Trials for Medical Devices and Drugs Relating to COVID-19 , made by the Minister on May 23, 2020, and published in the Canada Gazette, Part I, on June 6, 2020. IO No. 1 was replaced on May 3, 2021 by IO No. 2.
Qualified investigator
A person who is a member in good standing of a professional association of persons entitled under the laws of a province to provide health care under their licence in that province and who:
  • conducts the clinical trial or
  • is the responsible leader of a clinical trial conducted by a team
Research ethics board
A body that is not affiliated with an applicant for a COVID-19 medical device or drug authorization, or a holder of such an authorization, and whose principal mandate is to approve the initiation of, and conduct periodic reviews of, biomedical research involving human subjects to ensure the protection of their rights, safety and well-being.

Note about guidance documents in general

Guidance documents provide assistance to industry and health care professionals on how to comply with governing statutes and regulations. They also provide guidance to Health Canada staff on how mandates and objectives should be met fairly, consistently and effectively.

Guidance documents are administrative, not legal, instruments. This means that flexibility can be applied by industry. However, to be acceptable, alternate approaches to the principles and practices described in this document must be supported by adequate justification. They should be discussed in advance with the relevant program area to avoid the possible finding that applicable statutory or regulatory requirements have not been met.

As always, Health Canada reserves the right to request information or material, or define conditions not specifically described in this document, to help us adequately assess the safety, efficacy or quality of a therapeutic product. We must make sure that such requests are justifiable and that decisions are clearly documented.

This document should be read in conjunction with the accompanying notice and the relevant sections of other applicable guidance documents.

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