Clinical trial operations

The trust layer for AI agents inside subject screening, consent, adverse-event triage, and protocol-deviation flagging workflows.

Clinical trial operations move at the speed of protocol amendments and patient enrolment, not at the speed of investigator review. The clinical-trial sub-vertical pack codifies the actions an agent may take inside a trial, gates the safety-critical and subject-facing actions behind clinician or trial-coordinator approval, and signs every decision into an audit chain an external auditor can verify offline. ICH E6(R2) traceability flows through the principal-chain on every governed action; FDA Part 11 signature / record linking flows through the per-tenant Merkle chain.

Which frameworks the life sciences pack maps to today.

Framework
Jurisdiction
Coverage
Notes
FDA 21 CFR Part 11
vortalis_proxy/compliance/fda_21_cfr_part_11.py
tests/conformance/regulators/fda_21_cfr_part_11/
US
Full
Subpart B (Electronic Records: 11.10, 11.30, 11.50, 11.70) and Subpart C (Electronic Signatures: 11.100, 11.200, 11.300) mapped to platform primitives. Operator-side controls (validation summary, training records, signature-meaning SOPs, physical-security posture) are explicitly NOT_AVAILABLE_IN_PLATFORM and the operator supplies them.
ICH E6(R2) Good Clinical Practice
vortalis_proxy/compliance/ema.py (build_ema_sections)
tests/conformance/regulators/ich_e6_r2/
International (EMA / FDA / MHRA adopted)
Full
Section 5.5.3 (electronic data systems) covers audit trail, security, validation, and ALCOA+ properties of trial data. ICH E6(R3) is in advanced revision; the builder will be revisited when R3 is adopted.
EMA Reflection Paper on AI
vortalis_proxy/compliance/ema.py
tests/conformance/regulators/ema/
EU
Partial
The Reflection Paper (EMA/CHMP/CVMP/83833/2023) is the EMA's published position; it is by its own framing non-binding. The builder cites the published positions and explicitly marks anticipated requirements where the EMA has signalled future development.
MHRA Software as a Medical Device
vortalis_proxy/compliance/mhra.py
tests/conformance/regulators/mhra/
UK
Partial
Yellow Card audit support, DCB0129 / DCB0160 clinical risk management, post-market surveillance, SaMD transparency, and an explicitly anticipated AI/ML lifecycle section. The companion AI/ML extension is at vortalis_proxy/compliance/mhra_samd.py.
HIPAA Security Rule
vortalis_proxy/compliance/frameworks.py (build_hipaa_sections)
tests/conformance/regulators/hipaa/
US
Full
Where US trials are in scope, HIPAA technical safeguards (access control, audit controls, integrity controls, authentication, transmission security) are mapped to platform primitives. Physical safeguards are NOT_AVAILABLE_IN_PLATFORM.

Upstream services Vortalis adapts for this vertical.

No Vortalis-side adapters ship for this vertical today. The calling system holds the upstream credentials (CTMS / EDC, safety database, subject-communication channels) and Vortalis governs the action at the agent boundary rather than at the upstream-API boundary.

The policy template for this vertical.

Actions allowed

13

Each action gated by policy at the hot path.

Anticipated require_human actions

  • consent.renewed
  • adverse_event.flagged
  • protocol_deviation.flagged
  • eligibility.confirmed
  • patient.communication_sent

Rate-limit posture

200 subject.screened per 24-hour rolling window; 50 eligibility.confirmed per 24-hour rolling window; 100 adverse_event.flagged per 24-hour rolling window; 100 protocol_deviation.flagged per 24-hour rolling window; 100 patient.communication_sent per 24-hour rolling window. Defensible for a single-site trial; multi-site sponsors raise after agreement with the medical monitor.

Template path: policies/sectors/life-sciences/clinical-trial-template.yaml

The implementation guide your engineers read first.

Available

docs/governance/integration-briefs/life-sciences-clinical-trial.md

What this sector pack does not do.

Vortalis does not perform clinical decisions; AI agents do.

The policy template gates 13 actions including subject.screened, adverse_event.flagged, and consent.renewed. It does not screen the subject, judge the seriousness of an adverse event, or substitute for the investigator's or medical monitor's clinical judgement. Trial integrity, subject safety, and the sponsor's regulatory obligations remain the operator's responsibility. Vortalis records what the agent did and when; it does not grade what the agent recommended.

ICH GCP section 4.8 informed-consent obligations are unforgiving; the require_human flow on consent.renewed is mandatory.

ICH E6(R2) section 4.8 imposes specific obligations on informed consent that the investigator (not the AI agent) discharges. The policy template gates consent.renewed behind require_human so the investigator approval is captured on the audit chain alongside the consent-renewal action. A trial that allows consent renewal without investigator sign-off has a GCP gap.

Adverse-event regulatory-reporting timelines are the sponsor's; the platform records the QPPV-side approval but does not chase the regulator deadline.

FDA expedited safety reporting, EMA EudraVigilance reporting, and MHRA Yellow Card reporting each have their own timeline windows. The Vortalis chain captures the agent's triage, the medical-monitor or QPPV sign-off, and the post-hoc record of the actual regulator filing; the deadline tracking and the regulator-portal upload sit with the sponsor's pharmacovigilance team. The pharmacovigilance sub-vertical brief at docs/governance/integration-briefs/life-sciences-pharmacovigilance.md covers the PV-specific flow.

Part 11 validated state is an operator-level conclusion; the platform's runtime controls are necessary but not sufficient.

FDA 21 CFR Part 11 compliance is achieved by the operator's validated deployment. The platform supplies the cryptographic audit chain, ES256 signing, RBAC, encryption at rest, and the signature / record linking property; the operator's IQ, OQ, PQ, validation summary report, SOPs on signature meaning, training records, and physical-security posture sit alongside the platform.

The general-purpose honest limits sit at /security/limitations; this list is specific to the life sciences pack.

Bring Vortalis to your life sciences agents.

Read the integration brief if you would rather start with the engineering detail. Talk to us first if you would rather start with a conversation about your threat model.