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Approval· Regulatory Intelligence Briefing

What actually drives a PPB review timeline

4 December 20255 min read· Ultra Pharma Advisory Practice

Review duration is mostly a function of dossier quality and query handling. Where the time goes, and which parts an applicant controls.

Review timelines are usually discussed as though they were a property of the authority. In practice most of the variance sits with the applicant, in two places: the state of the dossier at submission, and how queries are handled once they arrive.

Where the time actually goes

A review is not a single continuous assessment. It is a sequence of assessment periods separated by clock stops, and the clock stops are where dossiers lose months. Each query issued and each incomplete response extends the elapsed time by considerably more than the drafting effort suggests, because the file re-enters a queue rather than resuming where it paused.

The consequence is that a dossier which triggers six queries does not take six units longer than one that triggers two. It takes longer than that, and the difference compounds.

What an applicant controls

Three things, mostly.

Completeness against the requirements that actually apply. Classification determines the requirement set, and a misclassified product generates queries that are really a disagreement about which rules govern the file. Resolving that after submission is expensive. A gap analysis before submission is not.

Internal consistency. Where the quality section and the clinical section describe the same product differently, an assessor has to ask. Cross-referencing a dossier against itself before filing removes a class of query entirely.

Query response quality. A response that answers the question asked, with the evidence attached, closes an item. A response that reframes the question generates a follow-up. The single highest-leverage practice is treating each query as a closure with evidence rather than as correspondence.

What this means for planning

Build the filing plan around query load rather than around a nominal review period. A pre-submission audit, an agency-ready narrative, and checklist-driven gap closure are not process overhead: they are the levers that move the date. The applicant sets the number of stops. The authority sets only the length of each one.

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