Health Canada has issued a new Guidance Document pertaining to biosimilar drug submissions. The new Guidance significantly reduces the supporting clinical safety and efficacy data that biosimilar applicants are required to submit as part of a new drug submission. It also removes the previous requirement for biosimilar manufacturers to provide a detailed rationale justifying approval for each indication being sought.

A draft version of the new Guidance was published by Health Canada in June, 2025. Health Canada received input from 15 stakeholders, said to represent biopharmaceutical companies, industry associations, patient organizations and a member of the public, before finalizing the new Guidance. Health Canada has not posted the stakeholder submissions.

Elimination of need for comparative clinical efficacy studies

Prior to the new Guidance, biosimilar sponsors were generally required to submit comparative clinical data against a Canadian reference biologic drug (CRBD), including a Phase III clinical study that demonstrated the absence of clinically meaningful differences in efficacy, safety and immunogenicity.

The revised Guidance shifts the focus of biosimilar submissions away from comparative clinical evidence to analytical evidence. Health Canada now emphasizes that “structural and functional studies are generally considered more sensitive than clinical studies for detecting differences between a biosimilar candidate and its CRBD.” Sponsors are now expected to establish similarity through non-clinical comparative physicochemical, functional and stability studies.

Clinical study requirements are limited to a comparative pharmacokinetic study in healthy subjects. Pharmacodynamic endpoints may be added to the study, if feasible. The new Guidance summarizes the significantly reduced clinical study requirements as follows:

The clinical studies required to support the authorization of a biosimilar are generally limited to a comparative pharmacokinetic trial conducted to demonstrate pharmacokinetic equivalence between the biosimilar and the CRBD. The study is also expected to collect data on safety and immunogenicity. Pharmacodynamic endpoints may be included, if feasible. Comparative clinical efficacy studies are not typically required for a biosimilar candidate to a CRBD when the biosimilar can be compared and extensively characterized by appropriate analytical studies. If comparative clinical efficacy studies are included, the sponsor should explain the role of the studies and the value of results in the context of the submission.

Removal of scientific rationale for indications

Sponsors are no longer required to provide a detailed scientific rationale supporting authorization of each indication claimed for a biosimilar.

Health Canada now provides that where a biosimilar candidate has been shown to be highly similar to the CRBD and can deliver the same dosage as the CRBD for the relevant indication, “all the indications granted to the CRBD can be applied to the biosimilar candidate without further justification.”

This change eliminates the previous requirement for sponsors to provide a separate scientific rationale supporting each indication sought. However, Health Canada notes that any differences identified between the biosimilar and the CRBD will continue to be assessed on a case-by-case basis and may require additional evidence.

Overall, the new Guidance reduces the scientific and submission requirements for biosimilar submissions. These changes may result in accelerated biosimilar development and market entry in Canada. Health Canada has also published a summary of the changes from its previous biosimilar Guidance.

If you have any questions about the new guidelines, please reach out to the authors or a member of Gowling WLG’s Life Sciences sector group.