Opening the book…
What are INDs?
In this section we will cover the Investigational New Drug Application (IND) used for CBER-Regulated products such as vaccines.
An Investigational New Drug Application (IND) is a request from a clinical study sponsor to obtain authorization from the Food and Drug Administration (FDA) to administer an investigational drug or biological product to humans. Clinical studies are often conducted to collect safety and effectiveness information in support of marketing applications for biologic and drug products. Unless exempted, the sponsor for a clinical study must obtain authorization from FDA for conducting the study by submitting an IND application. Such authorization must be secured prior to interstate shipment and administration of any new drug or biological product that is not the subject of an approved New Drug Application or Biologics Product License Application.
Current Federal law requires that a drug be the subject of an approved marketing application before it is transported or distributed across state lines. Because a sponsor will probably want to ship the investigational drug to clinical investigators in many states, it must seek an exemption from that legal requirement. The IND is the means through which the sponsor technically obtains this exemption from the FDA.
During a new drug's early preclinical development, the sponsor's primary goal is to determine if the product is reasonably safe for initial use in humans, and if the compound exhibits pharmacological activity that justifies commercial development. When a product is identified as a viable candidate for further development, the sponsor then focuses on collecting the data and information necessary to establish that the product will not expose humans to unreasonable risks when used in limited, early-stage clinical studies.
FDA's role in the development of a new drug begins when the drug's sponsor (usually the manufacturer or potential marketer), having screened the new molecule for pharmacological activity and acute toxicity potential in animals, wants to test its diagnostic or therapeutic potential in humans. At that point, the molecule changes in legal status under the Federal Food, Drug, and Cosmetic Act and becomes a new drug subject to specific requirements of the drug regulatory system.
The overall process for vaccine development and approval includes:
- Research and Development
- Pre-clinical trials with non-humans
- The filing of an Investigational New Drug (IND) application with the FDA at the conclusion of pre-clinical trials requesting proceeding to in-human testing
- Pre-licensure vaccine Clinical Trials (Phases 1, 2, and 3)
- Filing a Biologics License Application (BLA) at the conclusion of Clinical Trial Phase 3 with the FDA
- Inspection of the pharmaceutical company's manufacturing facility or facilities and achieving approval
- Presenting the pharmaceutical company's findings to the FDA's Vaccines and Related Biological Products Advisory Committee (VRBPAC)
- Usability testing of the vaccine product labeling.
There are three IND types:
- An Investigator IND is submitted by a physician who both initiates and conducts an investigation, and under whose immediate direction the investigational drug is administered or dispensed. A physician might submit a research IND to propose studying an unapproved drug, or an approved product for a new indication or in a new patient population.
- An Emergency Use IND allows the FDA to authorize use of an experimental drug in an emergency situation that does not allow time for submission of an IND in accordance with 21CFR, Sec.312.23, or Sec. 312.20. It is also used for patients who do not meet the criteria of an existing study protocol, or if an approved study protocol does not exist.
- A Treatment IND is submitted for experimental drugs showing promise in clinical testing for serious or immediately life-threatening conditions while the final clinical work is conducted and the FDA review takes place.
There are two IND categories:
- Commercial
- Research (non-commercial)
The IND application must contain information in three broad areas:
- Animal Pharmacology and Toxicology Studies: Preclinical data to permit an assessment as to whether the product is reasonably safe for initial testing in humans. Also included are any previous experience with the drug in humans (often foreign use).
- Manufacturing Information: Information pertaining to the composition, manufacturer, stability, and controls used for manufacturing the drug substance and the drug product. This information is assessed to ensure that the company can adequately produce and supply consistent batches of the drug.
- Clinical Protocols and Investigator Information:
- Detailed protocols for proposed clinical studies to assess whether the initial-phase trials will expose subjects to unnecessary risks.
- The qualifications of clinical investigators: professionals (generally physicians) who oversee the administration of the experimental compound in order to assess whether they are qualified to fulfill their clinical trial duties.
- Commitments:
- to obtain informed consent from the research subjects,
- to obtain review of the study by an institutional review board (IRB), and
- to adhere to the investigational new drug regulations.
Once the IND is submitted, the sponsor must wait 30 calendar days before initiating any clinical trials. During this time, FDA has an opportunity to review the IND for safety to assure that research subjects will not be subjected to unreasonable risk.
Emergency Use INDs:
Emergency Use IND allows the FDA to authorize use of an experimental drug in an emergency situation that does not allow time for submission of an IND in accordance with 21CFR , Sec. 312.23 or Sec. 312.20. It is also used for patients who do not meet the criteria of an existing study protocol, or if an approved study protocol does not exist.
Regulatory Compliance:
Clinical studies must follow a set of laws and regulations, which are intended to protect the rights, safety, and welfare of human subjects participating in human trials, ensure the quality, validity, and integrity of the clinical trial data, and promote the availability of new medical products to the public. These laws and regulations define the roles and responsibilities of entities, such as sponsors, clinical investigators, and institutional review boards. In addition, various guidance documents and standard operating procedures are available to clarify policies and procedures for the IND process.
Frequently Asked Questions (FAQs)
- Q: When is an IND application required?
A: An IND application is required when a sponsor intends to conduct a clinical study involving the administration of an investigational product to humans, and the study is not exempt from IND requirements. Unless exempted, sponsors must obtain authorization from the FDA by submitting an IND application initiating administration of the investigational product.
- Q: How do I prepare to submit an IND application?
A: Sponsors should compile all necessary information and documentation required for the IND submission, including preclinical data, clinical trial protocols, manufacturing information, and safety monitoring plans. The submission should be prepared according to FDA regulations and guidance documents.
- Q: What are the key components of the IND application?
A: The content and format of an IND submission must be complete, well-organized as per 21 CFR 312, and include all applicable FDA Forms, provided below. These forms can also be found in FDA’s Form Database.
- Form FDA 1571: Investigational New Drug Application
- For Individual patient INDs, a licensed physician may use Form FDA 3926: Individual Patient Expanded Access IND in place of the Form FDA 1571
- Form FDA 1572: Statement of Investigator
- Form FDA 3454: Certification: Financial Interests and Arrangements of Clinical Investigators
- Form FDA 3455: Disclosure: Financial Interests and Arrangements of Clinical Investigators
- Form FDA 3674: Certification of Compliance
- Q: What happens after I submit an IND application?
A: After submission, the assigned CBER Regulatory Project Manager (RPM) will acknowledge receipt of the IND application to inform the sponsor that the application has been received. CBER will review the IND application to ensure compliance with regulatory requirements and assess the safety and scientific merit of the proposed clinical studies. The review process may include requests for additional information or clarification from the sponsor.
- Q: When can I initiate a study after I submitted an IND?
A: Only after CBER reviews the IND application within 30 days from the receipt and notifies the sponsor that the study is safe to proceed, the sponsor can initiate the clinical study. If the study is deemed not safe to proceed due to deficiencies, the IND is a subject to a clinical hold.
FDA Form 1571 Investigational New Drug Application [2]
Since FDA form 1571 Investigational New Drug Application is a project deliverable, let's take a look at what the three-page form looks like.
It will help inform what work is required and which team members will be assigned the needed work activities to prepare all the necessary supporting documents.
Instructions for completing Form 1571
The images of the IND form in Figure \(\PageIndex{2}\), Figure \(\PageIndex{3}\), and Figure \(\PageIndex{4}\) are explained in detail below.
Field 1: SELECT APPROPRIATE CENTER
CBER (FDA's Center for Biologics Evaluation and Research) is specified for a vaccine.
Field 2: NAME OF SPONSOR
- The sponsor is the person who takes responsibility for and initiates a clinical investigation. The sponsor may be an individual, pharmaceutical company, governmental agency, academic institution, private organization or other organization (21 CFR 312.3(b)).
- A Sponsor-Investigator is an individual who both initiates and conducts a clinical investigation and under whose immediate direction the investigational drug is being
- administered or dispensed (21 CFR 312.3(b)). For administrative reasons, only one individual should be designated as sponsor-investigator.
- If a pharmaceutical company will be supplying the drug, but will not itself be submitting the IND, the
- company is not the sponsor.
Field 3: DATE OF SUBMISSION
- Enter the date the submission is being submitted to the FDA. The date entered should match the date of the cover letter for the submission.
Fields 4–5: SPONSOR ADDRESS AND TELEPHONE NUMBER.
- Provide the address and telephone number of the sponsor identified in field 1 (21 CFR 312.23(a)(1)(i)). If this address is a post office box number, a street address should also be provided on line 2. The telephone number is the number where the sponsor is usually available during normal working hours.
Field 6: NAME(S) of DRUG
- For name(s) of drug (21 CFR 312.23(a)(1)(i)), list the established name(s) and trade name, if available. Also, provide the dosage form(s), and the unique ingredient identifier (UNII) term and code for active substances (if applicable). Use the Continuation Page if additional space is needed.
Field 7A: IND NUMBER
- Provide the IND number if it was previously assigned. If an IND number has not been assigned, leave the field blank. For IND numbers less than six digits, the IND number should be preceded using leading zeros (i.e., for IND 12345 enter 012345).
Field 7B: IND TYPE
- Select Commercial IND if the product under investigation is intended to be commercialized at a later date. (21 CFR 312.320).
- Select Research IND* if the product under investigation is not intended to be commercialized at a later date. Research INDs are generally sponsored by individual investigators, academic institutions and nonprofit entities. Includes INDs for emergency use or other expanded access. (21 CFR 312.310, 312.315 and 312.320).
Field 8A: PROPOSED INDICATION FOR USE
- Provide the proposed indication. Indicate if the proposed indication is for a rare disease (prevalence <200,000 U.S. patients). If the sponsor for the submission is the holder ofthe Orphan Designation Number, select “Yes” and provide the six-digit Orphan Designation Number in the appropriate field; if not, select “No.” Use the Continuation Page if there are more than one proposed indications for use by adding one indication per entry and providing rare disease/Orphan Drug Designation information for each entry, as applicable..
Field 8B: SNOMED CT INDICATION DISEASE TERM(S)
- For each original IND submission(including resubmissions to this submission type), provide the SNOMED
- CT coded disease term (e.g., 38341003 | Hypertensive disorder, systemic arterial (disorder) |) for the indication provided in Field 7A. To look up the indication’s SNOMED CT coded disease term:
- Navigate to IHTSDOTOOLS.
- Under Local Extensions, select ‘Go Browsing United States edition’.
- Select ‘Search’ tab located in the upper left hand of page.
- Enter the disease term in the search field.
- Check the box ‘Group by concept’.
- Select the single most appropriate term for the indication.
- Select the ‘Expression’ tab located in the upper right hand of page.
- Copy the entire text that appears under the heading ‘Pre-coordinated Expression.’
- Paste the copied SNOMED CT disease term into Field 7B of Form FDA 1571.
- For additional indications, use the continuation page for #7 and repeat these steps.
Field 9: PHASE(S) OF CLINICAL INVESTIGATION TO BE CONDUCTED
- Identification of the phase or phases of the clinical investigation to be conducted (21 CFR 312.23(a)(1)(ii)).
Field 10: CROSS REFERENCE
- It is necessary for the sponsor to submit certain information with an IND (such as manufacturing and controls information, pharmacology and toxicology data, or data from prior human studies) unless that information has previously been submitted to FDA. If the sponsor of the previously submitted information is not the same as the sponsor listed in field 2, the sponsor of the previously submitted information must provide a letter authorizing FDA to refer to the information (21 CFR 312.22(d)), (21 CFR 312.23 (b)). The sole exception to this requirement is when a marketed drug is used in the study, without modification to its approved packaging, in which case the marketed drug product must be identified by trade name, established name, dosage form, strength, and lot number (21 CFR 312.23(a)(7)(d)).
Field 11: SERIAL NUMBER
- IND submissions should be consecutively numbered. The initial IND should be numbered “Serial Number: 0000.” The next submission (e.g., amendment, report, or correspondence) should be numbered “Serial Number: 0001.” Submissions should be numbered consecutively in the order in which they are submitted.
Field 12A: SUBMISSION INFORMATION
Checklist of what is included in the submission:
- Initial Investigational New Drug Application (IND): Should only be checked for an original IND submission. For subsequent submissions, check ALL the boxes below that apply because the submission may contain more than one type of information:
- Response to Clinical Hold: A submission addressing deficiencies previously cited in a Clinical Hold Letter (21 CFR 312.42(e))
- Response to FDA Request for Information: A submission containing responses to information
- requests (21 CFR 312.41)
- Request for Reactivation or Reinstatement: A request to resume clinical investigation under an IND placed on inactive status (21 CFR 312.45(d)); or, terminated by FDA (21 CFR 312.44(d))
- Annual Report: A brief report of the progress of the investigation submitted within 60 days of the anniversary date that the IND went into effect (21 CFR 312.33)
- General Correspondence: Any communication between the sponsor and FDA pertinent to the IND (21 CFR 312.41)
- Development Safety Update Report (DSUR): A report that provides information to assure that sponsors are adequately monitoring and evaluating the evolving safety profile of the investigational drug; may be used in place of the Annual Report
- Other: Any submission that does not fit in the other categories.
Protocol Amendment(s) check list:
- New Protocol: A protocol for a study not covered by a protocol already contained in the IND (21 CFR 312.30(a))
- Change in Protocol: A submission describing changes in a protocol (21 CFR 312.30(b)), including changes to investigators (21 CFR 312.30(e))
- New Investigator: A new investigator added to carry out a previously submitted protocol (21 CFR 312.30(c))
- HF Validation Protocol: A protocol for a human factors (HF) validation study
- Use Related Risk Analysis: Used to analyze product tasks, risks, harms, and associated mitigations for the proposed product, can be used to support design of a HF validation study, or to support a justification that an HF validation study does not need to be submitted for Agency review.
Information Amendment(s): Select the scientific review discipline(s) to which the submission applies (21 CFR 312.31)
- Chemistry/Microbiology
- Pharmacology/Toxicology
- Clinical/Safety
- Statistics
- Clinical Pharmacology
Request For: Select the type(s) of request(s) contained within the submission.
- Meeting
- Proprietary Name Review
- Special Protocol Assessment
- Formal Dispute Resolution
IND Safety Report(s):
- Initial Written Report: 21 CFR 312.32(c)
- Follow-up to a Written Report: 21 CFR 312.32(d)
Field 12B
If the submission contains Digital Health Technology (DHT) data or a proposal to collect DHT data, select ‘Yes’. DHTs are systems that use computing platforms, connectivity, software, and/or sensors, (e.g., activity trackers, mobile medical applications) for remote data acquisition from participants in a clinical investigation. Although not final, FDA’s guidance on DHTs represents the Agency’s current thinking on the use of DHTs: FDA DHT information.
Field 13: COMBINATION PRODUCTS
Field 12A (Submission Information) should be filled out before attempting to fill out Field 13. Field 13 is only fillable for original submissions [i.e., the Initial Investigational New Drug Application (IND)]. Indicate if the product proposed within the submission is a combination product [e.g., drug-device, drug-biological product, drug-device-biological product, see 21 CFR 3.2(e)] by selecting ‘Yes’ and entering the number below that best identifies the type:
- Convenience Kit or Co-Package
- Prefilled Drug Delivery Device/System
- Prefilled Biologic Delivery Device/System
- Device Coated/Impregnated/Otherwise Combined with Drug
- Device Coated or Otherwise Combined with Biologic
- Drug/Biologic Combination
- Separate Products Requiring Cross Labeling
- Possible Combination Based on Cross Labeling of Separate Products
- Other Type of Part 3 Combination Product (e.g., Drug/Device/Biological Product)
If the product in the submission is not a combination product, select ‘No’ and leave the Combination Product Type blank. If the submission relates to both combination product and non-combination product configurations (e.g., the submission relates to a drug product in a vial and is also in a pre-filled syringe presentation), select ‘Yes’ and identify the type that applies to the combination product configuration. If the submission relates to a product configuration that has multiple combination product types (e.g., a submission
is for a product that contains a prefilled syringe (Type 2) and is co-packaged with other devices and drug (Type 1)), select type ‘9’. If this is the initial submission for a product for which a Request for Designation (RFD) was submitted, provide the six-digit RFD number.
Field 14. SUBMISSIONS REQUIRING A JUSTIFICATION STATEMENT
Select the following only if applicable. A justification statement must be submitted with the application for any items selected. Refer to the cited CFR section for further information.
Expanded Access Use, 21 CFR 312.300: Note that Treatment INDs and Treatment Protocols are not intended for single patient use. Before checking this box, the sponsor should be thoroughly familiar with the cited regulations and contact the appropriate FDA review division to discuss the proposed treatment use (21 CFR 312.320).
Field 15: CONTENTS OF APPLICATION
This section contains items 1 through 12 which is a checklist that should be used to indicate the types of information contained within a particular application or submission. Check all that apply.
- For a Sponsor-Investigator IND, Items 2–4 may be briefly addressed in the cover letter or in a summary.
- When the investigational drug is obtained from a supplier in a final dosage form, Items 5, 7, 8 and 9 may be referenced if authorization is given by the supplier (see explanation in field 9 above). If the investigational drug is prepared or altered in any way after shipment by the supplier, complete manufacturing (or compounding) and controls information, including information on sterility and pyrogenicity testing for parenteral drugs, must be submitted for that process in Item 7.
- Item 6 requires that a protocol be submitted, along with information on the investigators, facilities, and Institutional Review Board. Completed Form(s) FDA 1572 with attachments would suffice for Items 6 b–d.
- Item 7 also requires submission of either a claim of categorical exclusion from the requirement to submit an environmental assessment (21 CFR 25.15(a)). When claiming a categorical exclusion, the sponsor should include the following statements: “I claim categorical exclusion (under 21 CFR 25.31(e)) for the study(ies) under this IND. To my knowledge, no extraordinary circumstances exist.”
- In certain applications, information on special topics may be needed (Item 10). Refer to the cited CFR section for further information. Additional information may also include the Generic Drug User Fee (GDUFA) Coversheet (Form FDA 3794) for GDUFA Master Files (Type II APIs), when applicable.
- Include the Biosimilar User Fee Cover Sheet (Form FDA 3792) (Item 11) and / or the Clinical Trials Certification of Compliance (Form FDA 3674) (Item 12) as applicable.
The substantive items include:
- General investigational plan
- Protocol (study protocol, investigator data, and facilities data)
- Chemistry, manufacturing, and control data
- Pharmacology and toxicology data
Field 16
CONTRACT RESEARCH ORGANIZATIONS (CROs) Check the appropriate box to indicate if the clinical study will be conducted by a CRO. Use the Continuation Page to provide a statement containing the name and address of the CRO, identification of the clinical study and a listing of the obligations transferred (21 CFR 312.23(a)(1)(viii)).
Field 17
Provide the Name and Title of the person responsible for monitoring the conduct and progress of the clinical investigations (21 CFR 312.23(a)(1)(vi)). For Sponsor-Investigator INDs, the investigator has this responsibility.
Field 18
Provide the Name(s) and Title(s) of the person(s) responsible under 21 CFR 312.32 for review and evaluation of information relevant to the safety of the drug (21 CFR 312.23(a)(1)(vii)). For Sponsor-Investigator INDs, the investigator has this responsibility. Certain important commitments that the IND sponsor makes by signing Form FDA 1571 are listed below field 17. Under Section 744G (11) of the Federal Food, Drug, and Cosmetic Act (the FD&C Act), as added by the Biosimilar User Fee Act of 2012 (BsUFA), the term “financial hold” means an order issued by FDA to prohibit the sponsor of a clinical investigation from continuing the investigation if FDA determines that the
investigation is intended to support a biosimilar biological product application and the sponsor has failed to pay any required initial biosimilar biological product development (BPD) fee, annual BPD fee, or reactivation fee. The term “financial hold” does not mean that any of the bases for a clinical hold identified in section 505(i)(3) of the FD&C Act have been determined by FDA to exist concerning the investigation.
Field 19: NAME OF SPONSOR OR SPONSOR’S AUTHORIZED REPRESENTATIVE
For a sponsor-investigator IND, the sponsor-investigator should be named and must sign the form. For an IND sponsored by a pharmaceutical firm or research organization, the name of the sponsor’s authorizing representative should be entered and that individual must sign the form.
Fields 20–22
- Provide the telephone number, facsimile number, and full mailing address of the individual identified in field 19.
Field 23
- Provide the email address of the person identified in field 19. For INDs submitted to the Center for Biologics Evaluation and Research (CBER), a specific statement authorizing communication via non-secure email should be included in the cover letter as applicable.
Field 24
Provide the date the form is signed by the sponsor or sponsor’s authorized representative. This date may be different from the date provided in field 3.
Field 25: NAME OF COUNTERSIGNER
If the person signing the application in field 28 does not reside or have a place of business within the United States, the submission must be countersigned by an attorney, agent, or other authorized official who resides or maintains a place of business within the United States (21 CFR 312.23(a)(1)(ix)). If applicable, provide the name of the attorney, agent or other authorized official countersigning the application in field 29.
Field 26: ADDRESS OF COUNTERSIGNER
- If applicable, provide the full mailing address of the individual identified in field 25. If the sponsor or sponsor’s authorized representative identified in field 18 does not reside or have a place of business within the United States, this mailing address is the address to which written correspondence from the FDA should be directed.
Field 27: EMAIL ADDRESS
- Enter the email address of the Countersigner named in Field 25.
Field 28: SIGNATURE OF SPONSOR OR SPONSOR’S AUTHORIZED REPRESENTATIVE
- The person identified in field 19 must sign in this field (21 CFR 312.23(a)(1)(ix)).
Field 29: SIGNATURE OF COUNTERSIGNER
- If applicable, the person identified in field 25 must countersign in this field.
References
- FDA IND. Information downloaded January 7, 2026.
- FDA IND Form 1571 link. Form FDA 1571: Investigational New Drug Application. Information downloaded January 7, 2026.
- FDA IND Application. Accessed January 21, 2026.
- FDA IND Form 1571 instructions. Food and Drug Administration. "Instructions for Filling out Form FDA 1571 Investigational New Drug Application (IND). Accessed January 21, 2026.
- Food and Drug Administration, FDA Vaccine Approval Process (for the Illustration of the Vaccine Approval Process.)
2.9: Investigational New Drug (IND) Application is shared under a CC BY 4.0 license and was authored, remixed, and/or curated by LibreTexts.
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