The UK PSMF – What Will It Look Like?

How will the Pharmacovigilance System Master File (PSMF) be impacted by the UK’s departure from the EU?  What actions will companies with a UK Marketing Authorisation Holder (MAH)  need to take in the event of a no-deal Brexit? We consider the questions and give advice on what you need to consider and what you need to do if you are impacted. 


It is apparent that the MHRA will follow a similar approach to the EMA with respect to the management of PV activities, meaning that the following legal obligations will apply to a UK based MAH in a no-deal scenario:

  • Operation of a pharmacovigilance system
  • Appoint a QPPV that resides and operates in the UK
  • Maintain a PSMF (located in the UK)

What will the “UK PSMF” Look Like?

Firstly, the format and content of the UK PSMF are equivalent to that of the EU PSMF, so that’s helpful! Most MAHs are already familiar with the requirements of the EU PSMF and they follow the guidance outlined in GVP Module II. However, one should also be aware of the minimum requirements for the content and maintenance of the “UK PSMF” as laid out in HMR Schedule 12A.

Question: Do you have more than one PV system?

If so, the UK PSMF must describe the global PV operations and reflect the global availability of safety information for UK authorized products however, the annex content should be specific to UK authorized products.

Furthermore, all UK PSMFs must be registered with the MHRA and a unique PSMF number requested for each pharmacovigilance system for UK authorized products. Where the pharmacovigilance system is shared by several MAHs, a single request for a UK PSMF number should be submitted to the MHRA.

If you would like to speak to us about issues surrounding the above or seek our advice then call us on 00353 52 61 76706, e-mail us at: or complete the webform below and we will get back to you.


About the Author
Gemma Robinson, PhD
Managing Director
As Managing Director of Acorn Regulatory, Gemma Robinson is actively involved on client projects on a day to day basis and she leads a team of respected pharmaceutical, medical device, pharmacovigilance and clinical trial experts.  Gemma is also an active contributor to developing and promoting standards in the regulatory affairs profession and she has worked with a number of academic and not for profit organisations to encourage individuals to pursue a career in regulatory affairs and the broader STEM subjects. You can read more articles by Gemma by clicking the link below.
Other articles by Gemma Robinson PhD