The Health Research Authority (HRA) has published the findings from its pilot on researchers and sponsors of clinical trials and clinical investigations developing and submitting an Inclusion and Diversity Plan.
During the pilot, which ran for 6 months in 2025, the HRA and the Medicines and Healthcare products Regulatory Agency’s (MHRA) draft guidance on developing a Plan was tested by a small group of commercial and non-commercial researchers and sponsors.
The group submitted a Plan alongside their application for a Research Ethics Committee (REC) review.
The Plan helps researchers consider and demonstrate how they plan to enrol the full range of people who will use the drugs, devices or intervention they are testing.
The Plan also helps RECs to understand decisions researchers have made about who to recruit into their trials, to support discussions at the research ethics review meeting.
The development of the guidance was part of the HRA and MHRA's work to update the UK’s clinical trial regulations. While researchers and sponsors are encouraged to submit a Plan, it's not a legal requirement or part of the new clinical trials regulations that were introduced in April.
The guidance and its implementation also feeds into the wider cross-sector work of the UK Clinical Research Inclusion Group, to support greater access to, and inclusion in, clinical research.
The pilot findings
Seven studies took part in the pilot, including studies from commercial and non-commercial sponsors. Five of the studies were phase 3 Clinical Trials of Investigational Medicinal Products and two were for medical devices.
Overall, the findings from the pilot indicate that:
- researchers and sponsors who took part found benefit in developing a Plan at the point of study design
- the information that RECs need to see in the Plan and how it is presented to them needs further consideration
- the format of the guidance could benefit from further refinements to make it easier to find important information that researchers and sponsors need to complete the Plan
The guidance has now been updated in response to the pilot findings. The latest version of the guidance is available on the HRA website.
From early 2027 we will be asking more researchers and sponsors to volunteer to submit a Plan alongside their applications. Feedback will be collected over a 12 month period where we will gather further evidence on the benefits of developing a Plan. During this period, researchers and sponsors will be able to submit a Plan for review to one of a small number of participating RECs. You can express your interest in taking part by emailing engagement.team@hra.nhs.uk.
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