ICH E6(R3) makes software part of the clinical trial
The revised guideline on good clinical practice has applied in the EU since July 2025, and its Annex 2 follows on 15 January 2027. It no longer treats computerised systems as a side issue but as part of the data responsibility of sponsor and trial site. This article sets out what E6(R3) requires of software in clinical trials, what Annex 2 adds for wearables, apps and data from routine care, and how to align the effort with the risk.