The Initial FDA Hurdle: A Request for More Data
In January 2023, Eli Lilly received a Complete Response Letter from the U.S. Food and Drug Administration (FDA) concerning its application for accelerated approval of donanemab. The reason for the initial rejection was specific and related to the study's design, not a fundamental flaw in the drug itself. Lilly's Phase 2 trial, TRAILBLAZER-ALZ, allowed participants to stop treatment once their amyloid plaques were sufficiently cleared, a process that for many occurred within six months. As a result, the number of patients with at least 12 months of continuous drug exposure was insufficient for the FDA's requirements under the accelerated approval pathway. The FDA mandates robust long-term safety data, even when approving a drug based on a surrogate biomarker like amyloid plaque reduction. Donanemab's efficacy in removing amyloid was evident, but the short treatment duration for many participants meant the long-term safety and benefit information requested by the agency was not yet available.
The Turning Point: Full FDA Approval
Following the initial setback, Eli Lilly pressed on with its confirmatory Phase 3 trial, TRAILBLAZER-ALZ 2, which enrolled a much larger and more diverse population. The data from this trial, released later in 2023 and presented in peer-reviewed journals, demonstrated a significant slowing of cognitive and functional decline in patients with early symptomatic Alzheimer's disease. This comprehensive data package, which included long-term safety information, formed the basis for a new application for full FDA approval. In July 2024, the FDA granted this full approval, marking donanemab (brand name Kisunla) as the second Alzheimer's disease treatment to receive traditional approval based on solid Phase 3 data. This approval was seen as a major milestone, demonstrating that the FDA's initial rejection was a temporary hurdle related to data completeness, not an insurmountable barrier to the drug's eventual market entry.
The European Rejection: Risk vs. Benefit
While donanemab navigated a successful path to U.S. market access, it faced a different fate in Europe. In March 2025, the European Medicines Agency's (EMA) expert committee, the Committee for Medicinal Products for Human Use (CHMP), recommended against granting marketing authorization for donanemab. The core of the EMA's decision was that the benefits of the medication were not sufficient to outweigh the risks of potentially fatal events, specifically the known side effect of Amyloid-Related Imaging Abnormalities (ARIA). While the clinical trial data showed a modest slowing of disease progression, the EMA concluded that this benefit was too small to justify the significant safety risks, particularly brain swelling and bleeding associated with ARIA. This contrasted with the FDA's assessment, which found the benefits sufficient to warrant approval in the U.S..
Safety Concerns: A Closer Look at ARIA
ARIA, which presents as swelling (ARIA-E) or bleeding (ARIA-H) in the brain, is a significant safety concern for anti-amyloid antibody treatments like donanemab. While most ARIA cases are asymptomatic, severe and sometimes fatal events can occur. The risk of ARIA is heightened in individuals who carry the apolipoprotein E (ApoE) ε4 gene, a known risk factor for Alzheimer's disease. In the TRAILBLAZER-ALZ 2 trial, ARIA-E occurred in 24% of donanemab recipients, with 6.1% being symptomatic, and serious ARIA events led to three deaths. The EMA's committee, after considering the risks even within the non-ApoE ε4 population, maintained that the risk-benefit profile was unfavorable.
Regulatory Approvals and Rejections: Donanemab vs. Lecanemab
This regulatory divergence between the US and Europe for donanemab echoes the path of other anti-amyloid therapies. Lecanemab (Leqembi) also faced initial regulatory complexities but ultimately secured full FDA approval, though with a different dosing frequency and potentially lower ARIA rates compared to donanemab.
Feature | Donanemab (Kisunla) | Lecanemab (Leqembi) |
---|---|---|
Manufacturer | Eli Lilly and Company | Eisai and Biogen |
Mechanism | Targets a modified form of amyloid beta in established plaques | Targets soluble aggregated amyloid beta species (protofibrils) |
FDA Status | Full approval (July 2024) | Full approval (July 2023) |
EMA Status | Recommended refusal (March 2025), under re-examination | Recommended for approval (Nov 2024), initially refused |
Dosing Frequency | Monthly intravenous infusion | Bi-weekly intravenous infusion |
Treatment Discontinuation | Possible after achieving a predefined level of plaque clearance | Typically ongoing, but may switch to monthly maintenance dose |
Notable Side Effect | Higher reported rates of ARIA in trials | Lower reported rates of ARIA in trials |
Specialist Oversight | Requires MRI monitoring and specialist clinical settings | Requires MRI monitoring and specialist clinical settings |
The Broader Context of Regulatory Scrutiny
Beyond the specific data concerns, the donanemab regulatory journey reflects the broader challenges surrounding novel Alzheimer's treatments. Recent investigative journalism, such as a September 2024 article in The BMJ, has raised questions about the transparency and potential conflicts of interest within the FDA's advisory panel process for donanemab. Concerns were also raised regarding potentially incomplete safety records and the significant financial ties between expert advisors and pharmaceutical companies. This scrutiny highlights the intense pressure and high stakes involved in bringing potentially life-changing, yet risky, treatments to market for a devastating disease like Alzheimer's. It also underscores the varied approaches taken by different global regulatory bodies in assessing a drug's overall risk-benefit profile, with the EMA adopting a more cautious stance regarding donanemab's safety relative to its observed efficacy.
Conclusion
The path for donanemab was marked by significant regulatory hurdles. It was initially rejected for accelerated approval by the FDA due to incomplete long-term data, a specific consequence of its innovative trial design where many patients cleared their amyloid plaques quickly. While Eli Lilly successfully addressed this with more comprehensive Phase 3 trial data to secure full FDA approval, the journey didn't end there. The European Medicines Agency delivered a major rejection, deeming the clinical benefits insufficient to outweigh the risks, especially the potential for life-threatening ARIA. The story of donanemab's rejections serves as a powerful case study in modern pharmacology, illustrating the rigorous, and sometimes divergent, standards applied by global regulatory bodies when evaluating novel, disease-modifying therapies for complex and devastating conditions. It underscores the ongoing challenges of balancing innovative trial design, patient safety, and clinical efficacy in the highly scrutinized field of Alzheimer's treatment.
Visit the European Medicines Agency website for further details on drug evaluation procedures.