Application Pathways Updated January 14, 2026

What is a Complete Response Letter?

A Complete Response Letter (CRL) is FDA's notice that an application cannot be approved in its current form. Learn about CRL reasons and next steps.

Definition

Complete Response Letter (CRL) is FDA’s formal communication indicating that the review of an NDA, BLA, or supplement is complete but the application cannot be approved in its current form. The CRL identifies specific deficiencies that must be resolved.

How CRLs Work

When FDA identifies issues preventing approval, it issues a CRL by the PDUFA date instead of an Approval Letter. The CRL details all deficiencies and describes what the sponsor must do to address them.

Common CRL Reasons

  • Insufficient efficacy evidence from clinical trials
  • Unresolved safety signals or concerns
  • Manufacturing or CMC deficiencies
  • Facility inspection failures
  • Labeling or prescribing information issues
  • Inadequate risk management plans
OptionDescriptionTimeline
Respond with DataSubmit additional informationFDA reviews in 6 months (Class 1) or 10 months (Class 2)
Request MeetingDiscuss deficiencies with FDA30-60 days to schedule
Withdraw ApplicationDiscontinue pursuitImmediate
Dispute ResolutionFormal appeal processVariable

Why BD Teams Track CRLs

For business development professionals, CRLs represent critical risk factors:

  • Deal Implication: CRLs can significantly delay approval and affect deal valuations; milestone payments may be impacted
  • Due Diligence Focus: Understand CRL reasons and sponsor’s remediation strategy before investment
  • Opportunity Signal: Companies with CRL-stage assets may seek partners with expertise to address deficiencies

Frequently Asked Questions

What is a Complete Response Letter?

A CRL is FDA's formal notification that it cannot approve an application as submitted and lists deficiencies that must be addressed before approval can occur.

What happens after receiving a CRL?

Sponsors can respond with additional data, request a meeting with FDA, withdraw the application, or request formal dispute resolution.

How long do you have to respond to a CRL?

There's no formal deadline, but applications may be considered withdrawn if no response is received within one year of the CRL date.

What are common reasons for CRL?

Common reasons include insufficient efficacy data, safety concerns, manufacturing issues, labeling problems, or need for additional clinical studies.

Can a CRL be appealed?

Sponsors can request a meeting to discuss the CRL, submit additional data, or use FDA's formal dispute resolution process if they disagree with the decision.

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