Insight · Clinical Operations · United Kingdom

How to Submit a Device Clinical Trial in the UK: MHRA, HRA and REC

Submitting a device clinical investigation in the UK means satisfying three bodies, in the right order and with the right parallelism: the MHRA, a Research Ethics Committee (REC), and, for NHS sites, the HRA. Get the sequencing wrong and the start date slips, even when every document is sound.

Charline Petitdemange
Charline PetitdemangeLead Clinical Project Manager, Eclevar MedTech

This page walks through the UK clinical trial submission route step by step: the three approvals, how to run them in parallel, the timing rules, fees, and how Great Britain and Northern Ireland differ.

1 Three approvals

The three approvals

Running a device trial in the UK means satisfying three distinct approvals rather than one, and understanding how they relate is the foundation of a realistic plan. The regulator assesses the device and the investigation, the research ethics committee protects participants, and the governance approval clears the study at the level of the health system, and each has its own remit and timeline. Treating them as a single step, or assuming one substitutes for another, is the most common source of avoidable delay.

◆ Three bodies, run in parallel
  • MHRA notification: investigations of non-UKCA/CE-marked devices must be notified to the MHRA at least 60 days before initiation, via the IRAS portal. If the MHRA raises no grounds for objection within 60 days, the investigation may proceed.
  • REC opinion: a favourable opinion from one REC within the UK Health Departments Research Ethics Service is required (one REC, regardless of the number of sites), and can be obtained in parallel with the MHRA notification. The MHRA does not accept opinions from independent ethics committees.
  • HRA Approval: for NHS sites in England (and HCRW in Wales), HRA Approval combines governance and legal-compliance assessment with the REC opinion, and is required before the investigation starts at that site.
Recognition

Platinum Award, xShare & EUCROF Open Call 2026

Won by the Milo Health platform in the xShare Open Call for Clinical Research, the top Platinum tier: independent recognition, externally judged, scoped to what was awarded.

Platinum AwardRank 1EUCROF FederationAmsterdam · Feb 2026EU Co-Funded
Co-funded by the European Union. xShare Open Call for Clinical Research, organised by EUCROF. Amsterdam, 2 February 2026. Read the announcement →
2 Sequencing

Sequencing and timing

The investigation must not begin until the MHRA has raised no objection and the relevant REC opinion is in place; no NHS site in England may start until it also has HRA Approval and confirmed local management permission. Because the REC opinion can be sought in parallel with the MHRA notification, running the two tracks together is what protects the timeline.

A fee applies to the MHRA assessment. Amendments are submitted through IRAS and do not currently attract an MHRA fee; early termination or suspension must be notified within 15 days (24 hours if on safety grounds), and a final report is due within three months of the end of the investigation.

The three UK approvals, the regulator, the ethics committee and the governance approval, run on their own timelines, and the art of a fast UK start is sequencing them so they overlap rather than queue. A sponsor who submits them in the right order, with the dependencies understood, can shorten the path to first patient considerably compared with one who treats them as a strict sequence.

The regulator's notification timeline is the anchor most sponsors plan around, and building the rest of the schedule backwards from it, while preparing the ethics and governance submissions in parallel, is what keeps the UK leg from becoming the critical path. The documentation for all three can largely be prepared together, which is the practical key to running them concurrently.

Local knowledge shortens this further. A team familiar with how the UK bodies actually operate, what they expect in a submission and where applications commonly stall, prevents the avoidable queries and resubmissions that quietly add weeks, which is where a UK-experienced partner earns its place.

The art of a fast UK start is overlapping these approvals rather than queuing them. Because much of the underlying documentation is shared, the three submissions can largely be prepared together, and sequencing them so they progress in parallel, anchored on the regulator's notification timeline, can save weeks against a strict step-by-step approach. A sponsor who maps the dependencies in advance turns three serial hurdles into a coordinated, mostly concurrent process.

Talk to a reviewer

Planning a UK device trial?

Tell us your sites and device. We will sequence the MHRA, REC and HRA tracks so nothing waits on anything it did not have to, and your start date holds.

Free scopingMHRA via IRASUK sites
3 Documentation

Documentation

A complete submission centres on the clinical investigation plan (CIP), the investigator's brochure, the device description and risk documentation, the REC application, and the relevant forms via IRAS. Where standards are only partly met, the application should justify the alternative methods used to meet the essential or general safety and performance requirements.

Documentation is where UK submissions most often stall, usually over avoidable inconsistencies between the protocol, the participant-facing materials and the regulatory dossier. The bodies expect these to align precisely, and a mismatch generates queries that cost a cycle. Preparing the document set as a coherent whole, checked for consistency before submission rather than after a query, is a large part of what keeps the UK timeline on track.

4 GB and NI

Great Britain and Northern Ireland

Northern Ireland remains aligned with the EU MDR. Where an investigation includes sites in both Great Britain and Northern Ireland, a single submission to the MHRA made in line with the EU MDR can cover both - and by meeting the EU MDR, the UK MDR 2002 requirements for clinical investigations are deemed satisfied. This makes the GB/NI split far less painful than it first appears, provided the submission is built correctly.

The post-Brexit regulatory geography adds a dimension sponsors cannot ignore, because Great Britain and Northern Ireland do not sit in identical positions. A study that includes sites across the UK has to account for that difference rather than assume a single uniform framework, and a team familiar with the current arrangements prevents the kind of late surprise that can disrupt activation. Local knowledge of how the UK actually operates is what turns a potentially fiddly submission into a routine one.

Go deeper

Our UK CRO capability

See how we run UK device-trial submissions and post-Brexit pathways with in-country CRAs.

MHRAHRA / RECPost-Brexit
How Eclevar helps

Eclevar runs UK device-trial submissions end to end, MHRA via IRAS, the single REC opinion and HRA Approval, sequenced in parallel to protect your start date, with CRAs at UK sites and former Notified Body reviewers on the evidence. See our medical device CRO services.

Client proof

What clients say

★★★★★

It is my pleasure to recommend Eclevar MedTech as a scientific and clinical operations partner to any medical device company seeking evidence-led support under the EU MDR framework. Over the course of our engagement, Eclevar has consistently demonstrated the rare combination of regulatory rigour, clinical literacy and commercial pragmatism that our organisation requires.

Clinical and Regulatory Affairs
Mölnlycke Health Care AB
★★★★★

EU Notified Bodies do not automatically trust Japanese data. Eclevar translated our PMDA dossier into the language the NB needed to hear. One Q&A round. No major NCRs. We were genuinely surprised at how clean the review was.

EU Regulatory Affairs Lead
ASAHI INTECC (Class III Vascular Catheter)
★★★★★

Eclevar MedTech helped us with the CER and PMCF plan and defined the strategy to tackle the Notified Body questions and non-conformities.

Clinical Research Director
NIHON KOHDEN (Neurovascular)
The team

The people who would lead your file

Clinicians and a former Notified Body reviewer, named, not handed to a junior account team. Meet the full leadership team →

Prof. Mark DaCosta
Prof. Mark DaCosta
COO & CMO · Cardiovascular
Cardiac surgeon and former Notified Body reviewer (TUV SUD), Class III.
Chems Hachani
Chems Hachani
Founder & CEO
Architect of Eclevar's therapeutic departments and global corridors.
Pierre-Marie Boutanquoi
Pierre-Marie Boutanquoi
Head of Medical Writing
CER methodology, equivalence and Notified Body deficiency response.
Dr. Nikhil Khadabadi
Dr. Nikhil Khadabadi
CMO · Ortho & Spine
Class III implants, PMCF programmes and CER methodology.
Sebastien Meier Piantanida
Sébastien Meier Piantanida
Chief Data Officer · Biometry
30 years in biometry; architect of the MILO EDC, 21 CFR Part 11.
Charline Petitdemange
Charline Petitdemange
Lead Clinical Project Manager
Clinical investigation delivery and site monitoring across Europe.
FAQ

Device trials in the UK, answered

How far ahead must I notify the MHRA?

At least 60 days before initiating a clinical investigation of a non-UKCA/CE-marked device, via the IRAS portal. If the MHRA raises no objection within 60 days, the investigation may proceed.

How many RECs do I need?

One. A favourable opinion from a single REC within the UK Health Departments Research Ethics Service covers the investigation regardless of the number of sites, and can be sought in parallel with the MHRA notification.

What is HRA Approval and when is it needed?

HRA Approval (with HCRW in Wales) combines governance and legal-compliance assessment with the REC opinion for NHS sites in England and Wales; an NHS site cannot start until it has HRA Approval.

How are Northern Ireland sites handled?

Northern Ireland aligns with the EU MDR; a single MHRA submission made under the EU MDR can cover both Great Britain and Northern Ireland sites for the same investigation.

Sequence the tracks, hold the start date

Planning a UK device trial? We will sequence the MHRA, REC and HRA tracks so nothing waits on anything it did not have to, and your start date holds.

Talk to Eclevar

Reforming Clinical Evaluation of Medical Devices in Europe