Service · AI Governance

AI is already in your GxP environment.
The validation framework for it probably isn't.

Regulated organisations are deploying AI faster than their governance frameworks can keep pace. The validation questions this creates are not new. But applying them to systems that learn, adapt and change without a code release requires specific expertise. Senior, independent AI governance support from first risk assessment to inspection-ready evidence.

Where regulated
organisations get stuck.

AI introduces dynamic behaviour, opaque decision pathways and novel failure modes. The existing GAMP 5 and CSA frameworks provide a foundation. Applying them to systems that learn, adapt and change without a code release requires specific expertise.


FDA, EMA and MHRA are all actively developing AI guidance — including EMA's draft EU GMP Annex 22 on AI in GMP-regulated manufacturing, currently out for stakeholder and expert consultation, and the EU AI Act's broader risk-based framework, whose high-risk provisions may extend to AI used in regulated manufacturing and quality processes. Organisations deploying AI in GxP workflows now are setting their own inspection precedents. Getting governance right early is significantly less expensive than remediating it under inspection pressure.

01
No validated state for a system that changes continuouslyTraditional CSV assumes a fixed, releasable system. AI models update, drift and produce variable outputs. A governance model built for dynamic behaviour is required from the outset.
02
Audit trail gaps for AI-generated recordsGxP data integrity requirements apply to AI outputs. If the provenance of a model output cannot be traced to a specific model version, training data and configuration state, that is an ALCOA+ gap.
03
Change control not extended to model changesPrompt changes, configuration updates and training data changes are controlled changes in a GxP context. Without formal impact assessment and approval records, every model update is an uncontrolled change.
04
No documented position when regulators askInspectors are asking about AI governance now. Organisations without a documented intended use, risk classification and control framework have no defensible answer. There is no time to build one under inspection conditions.

A governance framework
built to withstand scrutiny.

A
AI Risk Assessment

Intended use definition, patient and product impact analysis, system categorisation and control rationale. The documented foundation regulators look for first.

B
Validation Strategy for AI Systems

A defensible assurance approach proportionate to risk and intended use, covering model behaviour, human oversight requirements and performance acceptance criteria.

C
Change Control Framework

Formal governance for model updates, prompt and configuration changes, and training data changes, with impact assessment templates and approval records.

D
Data Integrity Analysis

ALCOA+ gap assessment for AI-generated records: provenance traceability, audit trail design for model outputs, and input data governance.

E
Performance Monitoring Programme

Drift detection controls, periodic review cadence, defined thresholds and documented escalation paths. Demonstrates ongoing governance across the model lifecycle.

F
Supplier Qualification for AI Vendors

Qualification approach for AI platform and model vendors: shared responsibility matrix, change notification expectations and evidence of vendor quality system maturity.

What regulators
are already asking.

The regulatory frameworks for AI in regulated environments are actively developing. FDA, EMA and MHRA have all published or signalled guidance. Organisations that understand the direction of travel can build governance that holds, rather than retrofitting it after the first inspection observation.

FDA
AI/ML action plan and draft guidanceFDA's action plan for AI/ML-based software as a medical device signals a move towards predetermined change control plans. The underlying expectation applies across GxP environments regardless of device classification: document, control, evidence.
EMA
Reflection paper on AI, and a draft GMP Annex 22EMA's reflection paper sets out expectations for data governance, model transparency, change management and human oversight for AI used in the medicines development and manufacturing lifecycle. A draft EU GMP Annex 22, covering the use of AI (including generative AI) specifically within GMP-regulated manufacturing, is currently out for stakeholder and expert consultation via EMA's GMP/GDP Inspectors Working Group, in collaboration with the Quality Innovation Group; it is not yet finalised.
MHRA
Software and AI as a medical device guidanceMHRA's guidance framework for AI as a medical device is evolving post-Brexit. For GxP-adjacent AI applications, inspection teams are already applying existing data integrity and validation expectations to AI-generated outputs and records.
EU
EU AI Act — cross-sector, risk-based frameworkThe EU AI Act classifies AI systems by risk tier (unacceptable, high-risk, limited and minimal risk) and is not GxP-specific, but its high-risk provisions may extend to AI used in manufacturing and quality processes affecting product safety. Implementation timelines are under active EU legislative discussion; treat this as a separate compliance layer alongside sector guidance from FDA, EMA and MHRA, and verify the current position before relying on a specific date.

Frequently asked.

Does GAMP 5 apply to AI systems?
Yes, with additional controls specific to AI behaviour
GAMP 5 principles apply: risk-based categorisation, proportionate assurance, lifecycle management. AI introduces additional requirements around model versioning, drift monitoring and change governance that need to be layered on top of the existing framework.
Our LIMS vendor has added an AI feature. Do we need to revalidate?
A documented impact assessment is the minimum
A vendor-introduced AI feature is a change to a validated system. It requires a formal impact assessment, a risk decision on whether re-validation is triggered, and documentation of whatever controls are introduced for the AI functionality, including whether it touches GxP data.
How do we produce an audit trail for AI outputs?
Model version, input data and configuration: all traceable
An AI-generated record needs to be attributable to a specific model version, input dataset and configuration state at the time of generation. Designing that traceability into the system before go-live is significantly simpler than retrofitting it after an observation.

Governance experience across
AI and algorithmic systems.

AI governance in GxP environments encompasses a broad range of system types, from traditional algorithmic decision support to modern large language model integrations. The regulatory principles apply across all of them.

AI-enabled LIMS features Predictive analytics platforms Document AI / intelligent document processing LLM integrations in QMS Lab automation with ML components AI-assisted batch review Anomaly detection systems Natural language processing in regulatory submissions AI features in SaaS platforms Algorithmic decision support tools

AI already in your environment?
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Often needed alongside
AI governance.