After approval · annual · does not auto-renew

Nothing has to go wrong for you to lose it

An authorisation is not a document you file away. It is a calendar — renewal windows, retention fees, vigilance clocks measured in hours, and requirements that change underneath a product already on sale. In most of these markets the way companies lose a registration is not misconduct or failure. It is a date.

SOUTH AFRICA · A RULE THAT WAS ALWAYS THERE s. 15(6): “valid for a period of five years” on the statute book for years · not systematically enforced 21 AUGUST 2025 Switched on, for the whole register product-specific roadmaps, scheduled quarterly, through to 2035 2025 2035 Nobody who registered before 2025 has ever had to meet this deadline.
SAHPRA's words on missing it, or filing it incomplete: the registration expires. The rule did not change in August 2025 — the enforcement did, and the ten-year call-up means your turn is scheduled whether or not anyone told you.
48 hoursthe shortest vigilance clock on this page, and it binds your importer too
2035the end of South Africa's rolling renewal call-up — every registration is on it
Year ninewhen a Nigerian 5+5 product de-registers, by design, having done nothing wrong
Annualour maintenance, and it does not auto-renew — you re-decide every year
Why this is its own service

The expensive failures here are administrative, not technical

Nobody loses a registration because the product turned out to be unsafe. They lose it because a retention fee was not paid in June, because a renewal was filed at ninety days when the regulation says one hundred and eighty, or because the person who held the licence left the company and nobody told the regulator.

South Africa is blunt about the consequence: a licence allowed to lapse is not renewed — you apply for a new one, at the new-application fee, from the back of the queue, with your product off the market in the meantime. That is the whole risk of this service in a sentence, and it is why the work is a calendar rather than a skill.

A dormant rule can be switched on

Section 15(6) of the South African Medicines Act has said for years that a registration is valid for five years. It was not systematically enforced. As of a stakeholder communication dated 21 August 2025, it is — and SAHPRA is working through the entire register on a ten-year rolling call-up, scheduling product-specific roadmaps quarterly by applicant through to 2035.

Which means an obligation that nobody in your company has ever had to meet is now scheduled, and the schedule is not yours.

Twelve calendars

How long it lasts, when you must move, and what happens if you do not

Pick a market and a product type. The red panel is the consequence, because that is the part that decides how much this service is worth to you.

How long it lasts—

When you must file—

If you miss it

What recurs in between

    Hours, not months

    The vigilance clocks, and who they actually bind

    These are the deadlines nobody diaries, because they only start when something has already gone wrong. They are also the shortest deadlines in market access by an order of magnitude.

    Immediately
    Nigeria — a field safety corrective action, reportable on identification
    48 hours
    Nigeria — a serious public health threat
    2 days
    Nigeria — death or serious deterioration · Saudi Arabia — an FSCA, from the date of the letter
    10 days
    Nigeria — serious incidents · Saudi Arabia — the middle tier, and the window to update a Saudi-DI record
    30 days
    Nigeria — potential serious harm · Saudi Arabia — the longest tier

    Bars are proportional to the deadline, which is why the first three are barely visible — that is the point. The detail that turns this into a contract question: Nigeria's post-market surveillance guideline puts duties on manufacturers, marketing authorisation holders, importers and distributors. Your Nigerian partner carries a clock you are accountable for, and whether they will meet it is decided in an agreement, not in a guideline.

    Calendar days, from NAFDAC's post-market surveillance and reporting guideline for devices and IVDs effective 19 August 2025, and from SFDA's post-market surveillance requirements. Egypt: we could not find a device-specific post-market surveillance or adverse-event guideline on EDA's medical device page, and the 2026 good pharmacovigilance practice decree appears to concern medicines — we report that as not found rather than as absent.

    Moving targets

    Requirements that change under a product already on sale

    A registration granted under one rulebook can be renewed under another. These are the changes we are currently tracking for clients, each with the document that created it.

    • To 1 April 2028
      South Africa

      ISO 13485 becomes compulsory for establishment licence holders

      Phased in: required with renewals since 1 June 2025, with SAHPRA aiming to have verified every licence-holder's certificate by 1 April 2028. Two consequences, and the second is not obvious — the certificate has to come from a conformity assessment body SAHPRA itself recognises. We could not read the current roster of recognised bodies; the page would not render. Whether any UK body is on it is unverified, and worth establishing before you assume your existing certificate transfers.

    • From January 2026
      Nigeria

      Bioequivalence arrives at renewal, not only at registration

      A full study report became a prerequisite for new registration of an imported generic from January 2026, and bioequivalence is being pushed into renewals as well. A product that has sat on the Nigerian market for fifteen years on a bibliographic file can now meet a study wall at renewal. NAFDAC's guideline of 5 May 2025 is aligned to ICH M13 and does not require the study to be run in Nigeria — we read that as foreign data being acceptable, but NAFDAC has not said so in terms, so we mark it an inference from two documents rather than a quoted rule.

    • From May 2026
      Egypt

      Unique device identification and unified coding

      EDA's UDI guideline version 2/2026 was issued and became applicable in 05/2026, alongside Chairman Decree 161 of 2025 of 27 February 2025 on unified coding and traceability. For comparison: there is no UDI requirement at all in Nigeria or South Africa — Nigeria's gazetted regulation asks only for batch, lot and serial numbers and a barcode.

    • Since 6 October 2023
      Türkiye

      The desktop GMP route is gone, and certificate validity now depends on your scheme

      TİTCK abolished the desktop assessment route. Its foreign GMP guidance gives a certificate twelve years of validity for a site in a PIC/S country against nine otherwise, and three risk-based renewals against two. Which means your inspection calendar — and the fee attached to it — is set by where your factory is, not by what you make.

    • Annually, each year
      South Africa

      The single exit price ratchet

      Not a renewal, but the most consequential recurring event for a medicine. The only lawful price increase is the Minister's annual percentage — 1.47% for 2026 — and the update guideline of 24 October 2023 provides no out-of-cycle increase route at all. A price cut takes effect in two working days. Five years of this compounds into a number worth modelling before you launch, not after.

    The service

    What we actually hold

    A maintenance engagement is a calendar we own and a person who answers when a regulator writes. It is annual, it is quoted per market and per portfolio size, and it does not roll over automatically.

    Included

    • A dated calendar of every deadline attached to your authorisations, built from the regulator's own instruments
    • Renewals prepared and filed to the earlier of the two dates where a regulation and a guidance disagree
    • Variations — labelling, instructions for use, manufacturing site, pack, specification changes
    • Retention and annual fees diarised and paid, with receipts
    • Representative and licence-holder records kept current with the authority, including when a named individual changes
    • Regulatory change monitoring for your markets, reported when it affects you rather than monthly regardless
    • A named person to answer a regulator's letter inside its response window

    Not included

    • Acting as your pharmacovigilance system or qualified person — that is a licensed role and we do not hold it
    • Making the safety report or the corrective action decision for you; we run the clock, you make the call
    • Official fees, retention fees and representative charges, which are passed through at cost
    • New registrations, which are quoted as projects
    • Any commitment that a regulator will accept a late filing

    Where a regulation and a guidance disagree, we work to the stricter one. South Africa's General Regulations require a renewal application at least 180 days before expiry; SAHPRA's own guidance says 90. We file to 180 and treat 90 as the administrative floor, because the cost of being wrong in that direction is a lapsed licence rather than a late one.

    If it has already lapsed

    The three situations we are usually called about

    1. 01

      "We think a renewal was missed"

      First we establish what the register actually says, which is not always what your file says. Whether there is a route back depends entirely on the market: Egypt grants a product holding preliminary approval to proceed with re-registration a grace period of up to four years from expiry; South Africa does not renew a lapsed licence at all.

      Us, in days
    2. 02

      "Our representative has gone quiet"

      An unresponsive representative is a live regulatory exposure, not only a commercial annoyance — they hold duties the authority expects someone to discharge. We establish what is outstanding, what the authority has sent, and whether the appointment can be moved. See local representation.

      Us, with you
    3. 03

      "A requirement changed and nobody told us"

      Usually one of the five above. The question is whether it bites at your next renewal or immediately, and what the cheapest compliant route is. Occasionally the honest answer is that the product should be withdrawn from that market, and we will say so.

      Us
    Questions

    Asked when the first renewal comes round

    We registered through a distributor. Whose job is the renewal?

    Legally, whoever holds the authorisation. Practically, whoever remembers. If your distributor holds it, they also hold the decision about whether it survives — which is the argument made in full on the representation page.

    Can you maintain registrations you did not obtain?

    Yes, and most of what we maintain we did not file. We start by reconciling the register against your records, which takes days and occasionally produces a surprise.

    What does it cost?

    Quoted annually, on portfolio size and number of markets rather than on a percentage of anything. Official and retention fees are passed through at cost with receipts.

    Does it auto-renew?

    No, deliberately. Each year is quoted and agreed before it starts. A service whose whole value is watching deadlines should not rely on you forgetting one.

    Do you cover pharmacovigilance?

    We run the clocks and the correspondence. We do not act as your qualified person or your pharmacovigilance system — in several of these markets that role is licensed to a named individual with prescribed qualifications, and it is not ours to hold.

    How will we know something changed?

    You hear from us when it affects your products, with the instrument that created it and the date it bites. We do not send a monthly bulletin of everything that moved in six countries.

    Start

    Send the certificates, and we will build the calendar

    The first piece of work is a reconciliation: what is registered, to whom, until when, and what is outstanding. It is quick, it is quoted separately, and quite often it is the whole engagement.

    • Every certificate of registration or authorisation you hold, and in which markets
    • Who is named as the holder or representative on each, if you know
    • Expiry dates as you understand them — we will check them against the register
    • Any retention or annual fee you believe is being paid, and by whom
    • Correspondence from any of these authorities in the last two years
    • Whether a named individual holds anything for you, and whether they are still there
    • Any variation you know is pending — a site change, a pack change, a labelling update

    Mutual NDA before you send anything. If you are not sure what you hold, that is a normal starting point and the reconciliation exists for exactly that.

    The deadline you have never had to meet is still a deadline

    Most of what ends a registration is scheduled, published and avoidable. Someone has to be watching the calendar, and it does not have to be you.

    mail@bcabusiness.co.uk · +44 7342 901002 · WhatsApp

    Every deadline on this page traced
    to the authority that published it · 18 September 2026

    Where the deadlines come from

    1. Saudi Arabia, devices. MDS-REQ 11, Requirements for Post-Market Surveillance of Medical Devices, version 2 — the two, ten and thirty day reporting tiers and the field safety corrective action reportable within two days of the FSCA letter. MDS-REQ 7 version 4 — UDI data present in Saudi-DI when the device is placed on the market, with record updates inside ten working days. SFDA fee schedule, May 2025 — renewal SAR 5,000, label, IFU or advertising update SAR 1,100, Authorised Representative licence SAR 2,600 per year. Renewal may be filed from 90 days before expiry.
    2. Saudi Arabia, medicines. A marketing authorisation runs five renewable years, with renewal filed at least six months before expiry; the establishment licence also runs five renewable years. The statutory registration fee is SAR 1,000 per concentration, form or pack, on registration and again on renewal. Products priced under SAR 30 are exempt from re-pricing at renewal.
    3. United Arab Emirates. Federal Decree-Law 38 of 2024 — five-year validity, and the main establishment carrying licensing, pharmacovigilance and lifecycle management. EDE service pages — renewal of a device authorisation at AED 100 + 2,500 on a 15 working day period; a medicine renewal filed when six months or less remain, and a pack renewal when the pack has expired or expires within three months. EDE resolution adopting the pharmacovigilance practice guideline for medical products, July 2026.
    4. Egypt, devices. NP.CAMD.011 version 1/2025, March 2025 — annual plans, change, re-registration and new registration procedures, including the six-month extension of the grace period. GL.CAMD.003 version 03 — variations, with a first response in 8 working days and evaluation in 25, or 5 and 10 on the fast track. GL.CAMD.007 and GL.CAMD.008 version 02 — annual import approval per foreign factory and per-invoice customs release. UDI guideline version 2/2026, issued and applicable 05/2026. EDA Chairman Decree 161 of 2025, 27 February 2025 — unified coding and traceability.
    5. Egypt, medicines. Ten-year validity, re-registration applied for during the last year of validity, and a grace period of up to four years from the expiry date for a product holding preliminary approval to proceed with re-registration.
    6. Türkiye. TİTCK annual tariff, version dated 23 March 2026 — the fee lines. İDD-KLVZ-21 revision 10, 22 September 2025 — foreign GMP inspection, certificate validity of twelve years for PIC/S-country sites against nine, three risk-based renewals against two, and the abolition of the desktop assessment route on 6 October 2023. Beşeri Tıbbi Ürünler Ruhsatlandırma Yönetmeliği article 21 — renewal and indefinite validity thereafter. TİTCK announcement 2020/KK-3, 13 February 2020 — the validity of EC certificates from four named UK notified bodies truncated to 31 December 2020 in the national system, with no extension.
    7. Nigeria, devices. Guidelines for Post-Market Surveillance and Reporting of Medical Devices and In Vitro Diagnostics, PMS-GDL-024-00, effective 19 August 2025 — the 48-hour, 2, 10 and 30 calendar-day tiers, field safety corrective actions reportable immediately upon identification, and duties on manufacturers, marketing authorisation holders, importers and distributors. S.I. 42 of 2024, Gazette 176 volume 111, 16 October 2024 — regulation 4(7) five-year validity, regulation 12 post-market surveillance, regulations 16 and 19 labelling and packaging.
    8. Nigeria, medicines. Guidelines for Renewal of Certificate of Registration for Drug Products, DRR-GDL-025-04, effective 20 December 2024 — renewal on a 90 working day clock, the application due not later than six months before expiry, and a 45 working day query deadline. Directive NAFDAC-RDRT-038-00, effective 1 May 2025 — 240 working days for new, renewal and variation alike. NAFDAC "Five Plus Five-Year Validity (Migration to Local Production)" and "Commencement of Five Plus Five Year Validity" — de-registration at year nine. NAFDAC scientific guideline on bioequivalence, effective 5 May 2025, aligned to ICH M13.
    9. South Africa, devices. SAHPGL-MD-07 version 4, 21 May 2025 — five-year licences conditional on the annual retention fee each June, and SAHPRA's 90-day renewal guidance. General Regulations to Act 101 of 1965, regulation 24 — five-year validity and the 180-day renewal requirement. SAHPRA communication MD01-2025/2026 version 2, 18 September 2025 — the ISO 13485 phase-in, required with renewals from 1 June 2025 and verification targeted for 1 April 2028. SAHPRA media release, 4 April 2025 — affiliate membership of the Medical Device Single Audit Programme. SAHPGL-MD-18 version 1, 9 September 2025 — post-market surveillance and clinical follow-up.
    10. South Africa, medicines. Medicines and Related Substances Act 101 of 1965, section 15(6) — five-year validity. SAHPRA Communication HPA-RNW01-2025/26, 21 August 2025, Medicines Certificate of Registration Renewal Implementation Framework — renewal due six months before expiry with proof of fee payment, an updated electronic dossier baseline, the current certificate and the full variation history; product-specific roadmaps scheduled quarterly through to 2035; and the consequence of missing it or filing it incomplete. SEP Update Guideline 2023, 24 October 2023 — the notice periods and the absence of an out-of-cycle increase route. The 2026 single exit price adjustment of 1.47% is from Government Notice 6881, Government Gazette 53729, 28 November 2025, read from a scanned PDF and therefore marked secondary on the market page.

    What we could not confirm. We could not find a device-specific post-market surveillance or adverse-event guideline on EDA's medical device page, and the 2026 good pharmacovigilance practice decree appears to concern medicines — we report that as not found rather than as no obligation existing, since the transfer documents require an incoming applicant to commit to the device vigilance system, so one exists. We could not read SAHPRA's current roster of recognised conformity assessment bodies, so whether any UK body is on it is unverified. SAHPRA's variations addendum was blocked on every attempt.

    Each calendar sits in fuller context on the market page it comes from: all twelve are here.

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