Reporting Timelines and Where They Come From

Part of Principal Investigator (PI) Training: Safety Reporting and Unblinding.

About 4 minutes. Free, in your language, no account needed.

Why this matters

Almost every investigator has been taught that a serious adverse event must be reported to the sponsor within 24 hours. It is a useful working habit and it is not what ICH E6(R3) says. Knowing where each number actually comes from matters, because the source determines what applies to you, in your country, on this protocol.

What the guideline says

Section 2.7.2 sets out the investigator's safety reporting duties in four lettered points.

Note what is absent. There is no number of hours anywhere in that list. The guideline's word is immediately, qualified by after the investigator reasonably becomes aware.

Where the familiar numbers come from

NumberActual sourceWhat it governs
24 hours to report an SAE to the sponsorThe protocol or sponsor conventionSite to sponsor
7 calendar days for fatal or life-threatening suspected unexpected serious adverse reactionsUS regulation, 21 CFR 312.32Sponsor to FDA
15 calendar days for other suspected unexpected serious adverse reactionsUS regulation, 21 CFR 312.32; comparable clocks exist in other regionsSponsor to authority

Two practical consequences.

Your obligation is the protocol's. Read the safety section and find the actual number your protocol sets, because it is the one that binds you. Where the protocol says 24 hours, 24 hours is your rule — not because ICH says so, but because §2.7.2(a) points to the protocol and you signed it.

The 7 and 15 day clocks are mostly not yours. They are sponsor-to-authority obligations. But they run from the sponsor's awareness, which starts with your report — so a site that reports late compresses someone else's regulatory deadline. That is the real reason speed matters.

"Reasonably becomes aware"

The clock starts when you become aware, not when the event occurred. A participant hospitalized on Saturday and mentioned at Tuesday's visit generates awareness on Tuesday.

That makes awareness a process you can improve, and it is where sites actually lose time:

Fix the awareness path and the reporting timeline mostly takes care of itself.

Two rules that prevent most late reports

Report on suspicion, not on certainty. The initial report does not require a diagnosis, a causality assessment or a complete picture. It requires the sponsor to know. Waiting for the discharge summary before making the initial report is the most common cause of a late one — and §2.7.2(c) exists precisely so that detail can follow.

Delegate the mechanics, not the duty. Section 2.7.2(d) is explicit. Your coordinator can complete and submit the form. The obligation is yours, which means you need a way of knowing it happened — a same-day confirmation to you, or a log you review weekly.

Key takeaways