Application Pathways Updated January 14, 2026

What is Refuse to File?

Refuse to File (RTF) is FDA's decision that an application is too incomplete for substantive review. Learn about RTF criteria and how to avoid rejection.

Definition

Refuse to File (RTF) is FDA’s determination during the initial 60-day filing review that an NDA, BLA, or major supplement is so deficient that substantive review cannot proceed. An RTF means the application clock never starts.

How RTF Works

After receiving an application, FDA has 60 days to determine if it’s complete enough for filing. If critical elements are missing or the application is fundamentally deficient, FDA issues an RTF letter.

Common RTF Reasons

  • Missing or incomplete pivotal study reports
  • Insufficient bioavailability/bioequivalence data
  • Major CMC deficiencies
  • Unorganized or poorly indexed submissions
  • Missing safety data requirements
  • Incomplete electronic submission formatting

RTF vs CRL Comparison

AspectRefuse to FileComplete Response Letter
TimingWithin 60 daysAt PDUFA date
Review StageBefore substantive reviewAfter complete review
Application StatusNever formally filedReviewed but not approvable
PDUFA FeeMay require new feeAlready paid

Why BD Teams Track RTF

For business development professionals, RTF decisions signal regulatory preparation issues:

  • Deal Implication: RTF delays timeline significantly and may indicate sponsor inexperience with FDA process
  • Due Diligence Focus: Ask about pre-submission meetings and FDA feedback to assess RTF risk
  • Opportunity Signal: Companies recovering from RTF may need regulatory consulting partners

Frequently Asked Questions

What is Refuse to File?

RTF is FDA's decision within 60 days of submission that an application is too incomplete or deficient to proceed with substantive review.

When does FDA issue an RTF?

FDA issues RTF during the 60-day filing review period if the application lacks critical data, has major organizational problems, or is missing required sections.

What happens after an RTF?

Sponsors can request a Type A meeting to discuss deficiencies, then resubmit the application with corrections. A new PDUFA fee may be required.

How is RTF different from CRL?

RTF occurs before substantive review begins (within 60 days); CRL is issued after complete review when approval isn't possible.

Can you appeal an RTF decision?

Sponsors can request a meeting to discuss the RTF letter, but the standard approach is to correct deficiencies and resubmit.

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