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Medicinal product marketing authorisations in the UK: post‑Brexit framework, NI/Windsor arrangements, IRP recognition, accelerated routes, rolling review, variations and penalties

Practice notes
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This Practice Note outlines the law on marketing authorisations (MAs) for medicinal products intended for the UK market following the close of the Brexit transition period (11 pm (GMT) on 31 December 2020, termed in UK law ‘IP completion day’). It covers:

  • exemptions from the need to hold an MA (eg ‘specials’, investigational medicinal products (IMPs), and the Early Access to Medicines Scheme (EAMS))
  • the various categories of MA
  • the licensing pathways to secure an MA in the UK, Great Britain (GB), or Northern Ireland (NI) (eg Northern Ireland Medicines and Healthcare products Regulatory Agency (MHRA) Authorised Route (NIMAR), Innovative Licensing and Access Pathway (ILAP), unfettered access, the 150‑day accelerated national procedure, rolling review, the reliance routes on EU authorisations now integrated into the International Recognition Procedure (IRP), Project Orbis and Access Consortium)
  • information on applying the Ireland/Northern Ireland Protocol as amended under the Windsor Framework
  • the offences and penalties arising from breaches of these provisions

Governing law

The UK was a Member State of the EU from 1 January 1973 until 31 January 2020. During that period, the law...

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Web page updated on 21/05/2026

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