Introduction to Regulatory Considerations
According to the document “Points to Consider for the Efficacy Evaluation of Drugs for IgA Nephropathy (Early Consideration)” issued by the Pharmaceuticals and Medical Devices Agency (PMDA) on December 24, 2025 (https://www.pmda.go.jp/files/000278438.pdf), Japan has clarified its current regulatory thinking on the clinical efficacy evaluation of drugs for IgA nephropathy to support and accelerate drug development in this area.
IgA nephropathy is one of the most common forms of chronic glomerulonephritis and is characterized by hematuria and proteinuria caused by IgA deposition in the glomerular mesangium. Approximately 40% of patients progress to end-stage renal disease (ESRD) within 20 years after diagnosis. In Japan, IgA nephropathy is designated as an intractable disease, and there remains a significant unmet medical need due to the lack of established disease-modifying therapies.
Currently approved and commonly used treatments, including antiplatelet agents, renin-angiotensin system inhibitors, corticosteroids, and immunosuppressants, have not consistently demonstrated long-term renal outcome benefits. Similar challenges are observed globally, prompting active development of novel therapeutic agents.
Challenges in Efficacy Evaluation
ESRD is considered the gold-standard clinical endpoint for chronic kidney disease (CKD); however, trials using ESRD as the primary endpoint require long observation periods and are often impractical. As a result, alternative endpoints such as estimated glomerular filtration rate (eGFR) change, eGFR slope, and urine protein-to-creatinine ratio (UPCR) have been explored internationally.
Japan’s Early CKD clinical evaluation guideline defines Early CKD as eGFR ≥30 mL/min/1.73 m² and discusses the use of eGFR slope as a surrogate endpoint, including considerations on observation period and clinical relevance. Most IgA nephropathy trials target patients with mild to moderate renal impairment within this Early CKD population.
Use of Surrogate Endpoints
Short-term reduction in proteinuria, assessed by UPCR, has been increasingly recognized as a potential surrogate endpoint that may reasonably predict long-term renal function preservation. Several global Phase 3 studies have adopted trial designs in which UPCR is evaluated at earlier time points, followed by confirmation of eGFR slope over longer observation periods.
In the United States, for example, budesonide received accelerated approval for IgA nephropathy in 2021 based on proteinuria reduction, with full approval subsequently granted upon confirmation of long-term renal outcomes using eGFR data. These global regulatory precedents are referenced in the PMDA’s considerations.
Key Points for Efficacy Evaluation
Conclusion
This PMDA document provides important regulatory clarity on acceptable efficacy endpoints and trial designs for IgA nephropathy drug development in Japan. By outlining expectations for eGFR-based endpoints, the potential role of proteinuria as a surrogate marker, and the possible application of conditional approval, Japan aims to promote efficient development while maintaining scientific rigor.