Batch record review is still a top FDA finding

In FY2025, insufficient production record review under 21 CFR 211.192 was the second most-cited drug observation on FDA Form 483s, with 164 citations, or 5.8% of the total (GMP Insiders). In 2025 warning letters, “insufficient production record review and investigation (211.192, 22 citations)” was again among the leading issues (Pharmaceutical Online).

At the same time, QA teams are under pressure to release batches faster. Paper and hybrid records make that hard: reviewers read hundreds of pages to find the handful of entries that matter.

This guide covers what the regulations require, what changed for AI in GMP in 2025-2026, and how AI batch record review can speed release without weakening data integrity.

For what draft EU Annex 22 and FDA expect from AI in batch review and release, see AI for Batch Record Review and Batch Release: What It Can Do and Where Humans Must Decide.

What the regulations require

RequirementSourceWhat it means for review
Complete batch records21 CFR 211.188Records “shall include complete information relating to the production and control of each batch,” including in-process and lab results, yield and who performed and checked each significant step
QC unit review before release21 CFR 211.192All production and control records “shall be reviewed and approved by the quality control unit” before release
Investigation of discrepancies21 CFR 211.192”Any unexplained discrepancy” must be “thoroughly investigated, whether or not the batch has already been distributed,” extending to other affected batches
Data integrity (ALCOA)FDA data integrity Q&A guidance, Dec 2018Data must be “attributable, legible, contemporaneously recorded, original or a true copy, and accurate”
Audit trail reviewFDA data integrity Q&A guidance”all production and control records, which includes audit trails, must be reviewed and approved by the quality unit”

The last row is where electronic records raise the bar. ISPE’s 2026 review of audit trail practice quotes FDA: “Audit trails that capture changes to critical data must be reviewed with each record and before final approval of the record” (ISPE Pharmaceutical Engineering). Any AI-assisted review has to cover the audit trail, not just the batch record pages.

Europe is writing the first GMP rules for AI

The European Commission consulted from July 7 to October 7, 2025 on a revised Chapter 4, a revised Annex 11 and a new Annex 22 on artificial intelligence (European Commission). The draft Annex 22 “allows deterministic, static models for GMP critical applications,” “excludes generative AI and models with probabilistic output,” and “embeds mandatory human oversight at critical decision points” (PwC Belgium).

That position may soften. After its June-July 2026 workshop, EMA said it is “still considering the implications of the stakeholder consultation results,” and is seeking input on controls such as guardrails that could allow broader model types (EMA). As of October 2026, Annex 22 has not been finalized.

FDA is focused on credibility for a context of use

FDA’s January 2025 draft guidance on AI for drug and biological products sets out a “risk-based credibility assessment framework” for a model’s “context of use” (FDA). It is still a draft, and its scope for manufacturing uses is not spelled out on FDA’s page. Meanwhile, FDA’s voluntary Quality Management Maturity program entered its third prototype year in 2026 (Arnold & Porter), signaling continued interest in quality systems that go beyond minimum compliance.

Review by exception is the practical model

GAMP “promotes the use of review by exception” (ISPE), which MHRA defines as “A validated search tool that identifies and documents predetermined ‘abnormal’ data or actions.” EY describes review by exception shrinking a 150-page batch record review to a three-page exception report and cutting review cycle time “from days to hours” (EY).

Data integrity stays in the spotlight

In a review of 85 drug warning letters issued in 2025, “15% of all warning letters reviewed cited DI concerns” (Pharmaceutical Online). Faster review cannot come at the cost of weaker evidence.

Where AI fits in batch record review, and where it must not

The safest pattern in 2026 is AI as a reviewer’s assistant, not the release decision-maker. That matches both the draft Annex 22’s human-oversight requirement and 21 CFR 211.192, which places review and approval with the quality control unit.

Good uses of AIKeep with people (or deterministic, validated rules)
Flagging missing entries, signatures and dates against the master recordThe batch disposition decision
Highlighting out-of-range values, yield outside limits and late entriesDeciding whether a discrepancy is “explained”
Summarizing linked deviations, investigations and change controlsApproving investigations and CAPAs
Grouping audit trail events for the reviewerFinal audit trail review sign-off
Checking SOPs and master records against GMP requirementsChanging validated parameters or limits

Capabilities to require

  • Exception lists with source references. Every flag points to the page, field or audit trail entry behind it.
  • Deterministic checks for critical rules. Limits, required fields and signature checks run as validated rules; AI assists with context and summaries.
  • Complete coverage. The tool must show what it checked, so reviewers know what remains for manual review.
  • Deviation linkage. Link exceptions to deviations and investigations, including the § 211.192 extension to other affected batches.
  • Validation package. Intended use, risk assessment and test evidence your QA team can include in computerized system validation.
  • Data integrity controls. Audit trails, access control and e-signatures for the review itself.

Evaluation checklist for batch record review software

Evaluation areaAsk the vendorRed flag
Exception accuracyRun a historical batch with known deviations; are all found?Misses known issues or floods reviewers with noise
TraceabilityDoes each exception cite the record field or audit trail entry?Flags with no source
Audit trail coverageDoes it review audit trails of critical data, per FDA expectations?Only reviews the record pages
Model typeWhich checks use deterministic rules vs. AI models?Generative AI making pass/fail calls on critical data
Human oversightWho approves, overrides and signs, and is it logged?Automatic release
ValidationWhat validation documentation is provided for GxP use?”Validated by vendor” only
Regulatory watchHow will the tool adapt as Annex 22 is finalized?No roadmap for EU GMP AI rules

Pilot on closed batches first, where the right answer is already known, before using the tool on live release decisions.

Start with the documents behind the batch

Before you automate record review, make sure the procedures that govern it hold up. AskDona assesses SOPs, master records and investigation reports against the GMP requirements you choose, such as 21 CFR 211.188 and 211.192, and cites the passage behind every finding. Your QA team makes every decision.

Run a sample regulatory document assessment on your batch record review SOP.

FAQ

Can AI approve a batch for release? No. Under 21 CFR 211.192, the quality control unit must review and approve production and control records before release (LII). AI can prepare and prioritize the review.

What is review by exception? A validated approach that screens records and presents only predetermined abnormal data or actions to the reviewer, as defined by MHRA and promoted by GAMP (ISPE).

Is generative AI allowed in GMP-critical applications? Under the 2025 draft EU Annex 22, no: it is limited to static, deterministic models for critical uses. EMA is reconsidering after consultation, and the annex is not final (EMA).

Do audit trails need review for every batch? FDA expects audit trails that capture changes to critical data to be reviewed with each record before final approval (ISPE).

How common are 211.192 citations? In FY2025, 164 Form 483 citations, the second most frequent drug observation (GMP Insiders).

References

All pages opened and checked by October 9, 2026.

SourceTypeDateUsed for
eCFR: 21 CFR Part 211 Subpart JRegulation textCurrent§ 211.188
LII: 21 CFR 211.192Regulation text (mirror)CurrentRecord review, discrepancy investigation
FDA: Data Integrity and Compliance With Drug CGMP Q&ARegulator guidanceDec 2018ALCOA, audit trail review
FDA: AI to support regulatory decision-making (draft)Regulator guidanceJan 7, 2025Credibility framework
European Commission: Chapter 4, Annex 11, Annex 22 consultationRegulatorJul 7 – Oct 7, 2025Consultation scope
EMA: Annex 22 multistakeholder workshopRegulatorJun 30 – Jul 1, 2026Annex 22 still under consideration
PwC Belgium: Annex 22ConsultancyMar 31, 2026Draft Annex 22 scope
ISPE: Audit Trail Review in GxPIndustry journalMar/Apr 2026Review by exception, audit trails
Arnold & Porter: FDA QMM third yearLaw firmFeb 19, 2026QMM program
GMP Insiders: FY2025 FDA inspection observationsIndustry analysisJan 5, 2026§ 211.192 citations
Pharmaceutical Online: What FDA warning letters tell usExpert columnDec 15, 20252025 warning letter data
EY: Electronic batch recordsConsultancyApr 10, 2023Review by exception impact