Standard Operating Procedure for Transfer of Marketing Authorization or Product License
| Department | Regulatory Affairs |
| SOP No. | RA/2026/655 |
| Supersedes | NA |
| Page No. | 1 of X |
| Issue Date | 10/04/2026 |
| Effective Date | 10/04/2026 |
| Review Date | 10/04/2028 |
Purpose
This Standard Operating Procedure (SOP) defines the systematic process for the transfer of Marketing Authorization or Product License between entities in compliance with applicable regulatory requirements. It aims to ensure controlled, traceable, and timely transfer activities that maintain product registration integrity, regulatory compliance, and uninterrupted market supply while mitigating risks associated with documentation, approval, and submission processes.
Scope
This SOP applies to all activities involved in the transfer or change of Marketing Authorization or Product License for pharmaceutical products. It covers regulatory affairs personnel, product registration records, documentation, communication with regulatory authorities, and collaboration with cross-functional teams including Quality Assurance, Manufacturing, and Legal departments. The scope includes national and international transfers, any dosage forms or therapeutic categories, and excludes transfers not involving regulated product licenses or marketing authorization changes.
Responsibilities
The following roles are involved in the execution and oversight of the transfer process:
- Regulatory Affairs Executive – Preparation and submission of transfer dossiers
- Regulatory Affairs Manager – Review and approval of transfer documents and correspondence
- Quality Assurance – Verification of compliance and documentation control
- Legal Department – Assessment of contractual and licensing implications
- Regulatory Head – Final approval and liaison with health authorities
- Project Coordinator – Tracking timelines and communication facilitation
Accountability
The Regulatory Affairs Head is accountable for the implementation and ongoing compliance with this SOP. This role ensures periodic review, manages any escalations arising during the transfer process, evaluates SOP effectiveness, and enforces corrective actions to maintain regulatory alignment and continuous improvement.
Procedure
1. Preparation and Prerequisites
Identify the need for transfer initiated by business strategy or regulatory requirements. Gather all relevant product information including current Marketing Authorization dossiers, license certificates, regulatory correspondence, and existing commitments with authorities. Confirm the identity and regulatory status of the receiving entity.
2. Regulatory Assessment
Review regulatory frameworks of involved regions to identify mandatory documentation, fees, timelines, and authority-specific requirements. Determine if any supplementary data, stability studies, or variations are necessary to support transfer. Conduct risk assessment on impact to market supply and compliance.
3. Document Compilation
Assemble the transfer package including transfer request letter, updated product information, full product dossier, certificates of compliance, and completed application forms. Ensure that all forms are filled according to the receiving authority’s guidance. Maintain traceability of authorized signatures and document version control.
4. Internal Review and Approvals
Circulate compiled documents for multi-level review and approval within Regulatory Affairs, Quality Assurance, and Legal departments. Address queries or non-conformities identified during reviews. Obtain formal sign-off per organizational authorization matrix prior to submission.
5. Submission to Regulatory Authorities
Submit the transfer dossier to the relevant regulatory authorities by designated communication channels (e.g., electronic submission, courier). Secure acknowledgments and confirmation receipts. Monitor progress and respond promptly to any regulator queries or requests for clarification.
6. Post-Submission Follow-up
Track the review status regularly and document correspondence until final approval is granted. Coordinate with authorities for inspections or audits if required. Communicate status updates to stakeholders and prepare for any required labeling or packaging updates reflecting transfer.
7. Record Retention and Closure
Upon completion, archive all transfer documentation as per regulatory record retention policies. Document the closure status in internal systems and notify involved departments. Conduct a post-transfer review meeting to evaluate process adherence and identify improvement opportunities.
Adherence to Good Manufacturing Practice (GMP), Good Documentation Practice (GDP), and confidentiality throughout the procedure is mandatory. Any deviations must be reported and managed through the established deviation control process. All communications and actions must be documented accurately to support audit readiness.
Abbreviations
MA – Marketing Authorization
RA – Regulatory Affairs
GMP – Good Manufacturing Practice
GDP – Good Documentation Practice
QA – Quality Assurance
SOP – Standard Operating Procedure
Documents
The following documents are critical for the transfer of Marketing Authorization or Product License:
- Transfer Request Letter (Annexure-1)
- Regulatory Transfer Dossier Checklist (Annexure-2)
- Authority Acknowledgment Receipt Template (Annexure-3)
References
1. International Council for Harmonisation (ICH) Guidelines
2. EMA and FDA Regulatory Guidance on Marketing Authorization Transfer
3. WHO Good Regulatory Practices
4. Internal Quality Management System Documentation
5. National Drug Regulatory Authority Regulations applicable to product license transfers
Version
1.0
Approval
| Prepared By | |
| Checked By | |
| Approved By |
Annexures
Annexure-1: Transfer Request Letter
Purpose: To formally request transfer of the Marketing Authorization or Product License from the current holder to the receiving entity, ensuring clear communication with regulatory authorities.
| To | [Name of Regulatory Authority] |
| Date | 10/04/2026 |
| Subject | Request for Transfer of Marketing Authorization / Product License |
| Product Name | Example Product XYZ |
| MA Number / License No. | ABC123456 |
| Current MA Holder | Company A |
| Receiving Entity | Company B |
| Reason for Transfer | Business restructuring and regional affiliate alignment |
| Attachments | Transfer Dossier, Compliance Certificates, Application Forms |
We hereby request the transfer of the Marketing Authorization for the above-mentioned product as per the attached documentation and applicable regulatory frameworks. Please find enclosed all necessary documents for your review and approval.
Sincerely,
Regulatory Affairs Department
Company A
Annexure-2: Regulatory Transfer Dossier Checklist
Purpose: To ensure all required components of the transfer dossier are complete and submitted to regulatory authorities to facilitate approval.
| Document Description | Included (Yes/No) | Comments |
|---|---|---|
| Transfer Request Letter | Yes | Signed and dated |
| Product Dossier (CTD format) | Yes | Full updated submission |
| Current Marketing Authorization Certificate | Yes | Original valid certificate |
| Quality Compliance Certificates | Yes | GMP compliance included |
| Application Forms | Yes | Fully completed and signed |
| Legal Documentation/Contract Copies | Yes | Included as per internal requirement |
| Fees and Payment Receipts | Yes | Payment confirmed |
Annexure-3: Authority Acknowledgment Receipt Template
Purpose: To document receipt confirmation of the Marketing Authorization or Product License transfer application by the regulatory authority.
| Authority Name | [Regulatory Authority Name] |
| Application Number | TR-2026-000123 |
| Date Received | 15/04/2026 |
| Product Name | Example Product XYZ |
| MA Number / License No. | ABC123456 |
| Applicant Name | Company A |
| Contact for Correspondence | Regulatory Affairs Section |
| Remarks | Transfer application accepted and under review |
| Signature / Stamp | _________________________ |
Revision History
| Revision Date | Revision No. | Revision Details | Reason for Revision | Approved By |
| 10/04/2026 | 1.0 | Initial issue | New SOP creation |