Evidence · AI validation

AI is already running.
Annex 22 is coming.
The gap between them is open.

Generative AI is entering GxP documentation, SOP assistants, and deviation workflows — while regulation catches up via Annex 22. Most companies are prepared for neither.

This page is evidence under How we work. AI is not a field on the domain map but a step that appears in several fields.

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20222023202420252026 Coverage AI adoption Regulation ← Gap → Annex 22 consultation

Why act now

Regulatory pressure

The draft of EU GMP Annex 22 has been available since July 2025; the consultation has closed. Unvalidated AI systems in GxP processes become a direct audit finding upon entry into force — regardless of usage scope.

Competitive pressure

Competitors already use AI in documentation, deviation classification, and regulatory intelligence. Those who wait fall behind in ways that are hard to recover from.

Ungoverned internal use

Without policy and a validation framework, ungoverned AI pilots emerge in individual teams — creating a data situation no auditor will accept.

What is Annex 22? DRAFT

The first EU framework specifically for AI in pharmaceuticals.

EU GMP Annex 22 supplements Annex 11 (Computerised Systems) with ML-specific requirements. It covers AI systems that influence GxP-relevant decisions — regardless of whether the system is marketed primarily as AI. Section 1 of the draft expressly excludes Generative AI and Large Language Models from its scope; such models should not be used in critical GMP applications.

Regulatory status

Consultation closed 10/2025 → Final version pending → Entry into force

Lead time pays off: the draft expects controls for the independence of test data. Where they are split from a complete pool before training, those involved in development and training must never have had access to them — that cannot be established after the fact.

CORE REQUIREMENTS (DRAFT)

01

Risk-based classification of all AI/ML systems by intended use and decision depth

02

Demonstrable data quality: provenance, representativeness, and bias analysis of training data

03

Explainability: model decisions must be traceable and documentable for qualified personnel

04

Continuous monitoring: model performance tracked, drift detected and documented on an ongoing basis

05

Human oversight: critical GxP decisions require human control — no fully automated operation

Requirements based on the July 2025 consultation document; the numbering is our own and not a structure of the draft. Changes possible until the final version.

What is at stake

An unvalidated AI system in a GxP process is not a theoretical risk.

TRIGGER

Regulatory inspection or internal audit

FINDING

AI system in GxP process — not validated, no audit trail

Mandatory immediate revalidation

Production stoppage or batch hold

Reputational damage and follow-up inspections

The Significon approach

An AI model stays validated only as long as drift detection and revalidation keep running.

01

Use-case assessment

Which AI systems are GxP-relevant? Which are not?

02

Risk classification

GAMP5 category, decision depth, impact analysis

03

Validation plan

Test strategy, data quality, explainability concept

04

Implementation & test

IQ/OQ/PQ, bias tests, audit trail setup

05

Monitoring & review

Drift detection, periodic review, revalidation

We start with an assessment — a structured 60-minute workshop in which we jointly identify all AI systems in your GxP processes, prioritize them, and develop a concrete action plan. No engagement required.

The fundamental questions

Before the question "how?" comes: when am I even allowed — and under what conditions?

LLMs can barely be validated for their functionality — they are non-deterministic and internally unauditable. Those who deploy AI anyway must find a different answer: not "what does the model do" but "what does the process ensure".

01

When am I even allowed to use AI?

Only once proof is provided that risks are known, assessed, and controllable through appropriate measures. This is not a declaration of intent — it is an auditable proof that must exist before deployment.

02

Under what conditions is deployment defensible?

AI must not make quality-determining decisions on its own. The human-in-the-loop approach must be technically enforced and traceable — not through internal agreements that can be bypassed in operation.

03

How do I prove it?

Through process design that structurally produces the proof — not through retrospective documentation of an already running system. The process is validated, not the model.

The key concept

Validated by Design. With AI deployment, no longer a nice-to-have — a basic requirement.

Risk management becomes more important — not to reduce effort, but to make AI use possible in the first place. Proof that risks are known and understood is the entry ticket. Those who cannot provide it must not start.

Process before system before AI

First, the process must be fully understood and specified. Then the system that implements it. Only then does AI come — as an element within an already validated step, not as the driver of process design.

Enforce HITL technically, not by agreement

A human-in-the-loop based on agreements that can be bypassed in operation is not HITL. It must be technically enforced and traceable in the audit trail — who saw, evaluated, and approved which AI output, and when.

The quality of foundations is decisive

Clear roles and responsibilities in the organisation. Complete, consistent documentation. If these foundations are not solid: garbage in, garbage out — regardless of how good the AI architecture is. This is the most frequently underestimated core problem.

Camunda as governance tool

Validated by Design requires a tool that technically implements and versions process logic, HITL gates, and evidence strategy. Camunda is one tool that does this, and the one we use for it — a choice, not a necessity.

The result: The LLM is not validated — which is barely possible for non-deterministic models. Instead, the process is designed to structurally produce and make validity traceable. Conformity emerges through architecture, not through end-of-line control.

Why Significon

Criterion Typical approach Significon
Validation start After the system goes live Integrated into deployment planning
Documentation Retrospective, often incomplete Lifecycle-parallel, audit-ready
AI specifics Generic CSV templates Validation adapted to ML characteristics
Monitoring Optional, project-dependent Mandatory component, aligned with the Annex 22 draft
Regulatory basis Annex 11 applied by analogy Annex 11 + draft Annex 22 + EU AI Act

From our Insights

KI Annex 22 Orchestrierung

SAP, n8n and Annex 22: How regulated companies orchestrate AI workflows

Why classical SAP processes and new AI agents need a neutral orchestrator — and what this means for GxP compliance.

Read article →

Where does your organisation stand? 60 minutes — structured outcome.

In the use-case assessment we jointly identify all AI systems in your GxP processes, prioritize action needs, and define a concrete next step. No commitment, no follow-on pitching.

Request assessment → How we work