Clinical trials · EU market entry

Clinical trials in Europe: the legal representative your sponsor needs

A company from the United States, the United Kingdom, Switzerland or Asia that sponsors a clinical trial in the EU must appoint a legal representative that is established in the EU. That can be a contract research organisation. It can also be your own Dutch company, which later becomes the company that sells the product. This page explains the role and the Dutch route.

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In short

Clinical trials with medicines in the EU run under the Clinical Trials Regulation (CTR). Applications go through one portal, the Clinical Trials Information System (CTIS). A sponsor that is established outside the EU appoints a legal representative in the EU. That representative is responsible for the sponsor’s duties under the regulation and is the address for the authorities. Holdwise sets up the Dutch company that can be your legal representative, and works with clinical research and regulatory partners for the trial itself.

On this page: what the legal representative does, how the Dutch review works, why sponsors choose the Netherlands, and the steps from your first question to the first patient.

CTIS
one EU portal for every trial application since 2023; all trials run under the regulation since January 2025
EMA
the European Medicines Agency is in Amsterdam
1
legal representative in the EU for a sponsor outside the EU

What the legal representative does

The regulation says that a sponsor that is established outside the EU must ensure that a legal representative is established in the EU. The representative is responsible for making sure the sponsor meets its obligations under the regulation. Letters from the authorities go to the representative. The representative is named in the application in CTIS.

For a trial in more than one EU country the legal representative is always required. For a trial in one country only, that country may accept a contact person instead. Which option applies to your trial is checked with the authority of the country where the trial runs.

The legal representative is a role, not a licence. It can be a contract research organisation (CRO) that offers the service, a law firm, or a company in your own group. The choice matters for who signs contracts, who holds the data and who is liable.

A CRO or your own European company

A CRO as legal representative is the quick route for a first trial. The CRO already knows CTIS, the ethics committees and the inspectorate. The role ends when the trial ends.

Your own Dutch company as legal representative is the route for a sponsor that plans more than one trial in Europe, or that will sell the product in Europe afterwards. The same company then holds the trial contracts, the trial insurance and later the marketing authorisation. The knowledge, the relationships and the value stay in your group. A CRO still runs the trial day to day; your company signs and is responsible.

How a trial is reviewed in the Netherlands

In the Netherlands, trials with medicines are reviewed under the Medical Research Involving Human Subjects Act (WMO). The Central Committee on Research Involving Human Subjects (CCMO) coordinates the review and is the Dutch authority in CTIS. The ethical review is done by an accredited medical research ethics committee (METC) or by the CCMO itself.

The sponsor must have trial insurance for the participants under the Dutch insurance decree. The investigational medicine, if it is made outside the EU, is imported by a company with a manufacturing and importation authorisation for investigational medicinal products and released by a qualified person in the EU.

Trials with medical devices, called clinical investigations, follow the Medical Device Regulation and are also reviewed by the CCMO and an ethics committee. The sponsor outside the EU appoints a legal representative here too, unless the country accepts a contact person for a single-country study.

Why the Netherlands for European trials

The European Medicines Agency is in Amsterdam. Eight university medical centres, the Netherlands Cancer Institute and the Leiden Bio Science Park are within an hour of each other. Dutch investigators are used to international protocols, and English is the working language in hospitals, at the CCMO and at the tax office.

A Dutch company as legal representative is set up by power of attorney, with the parent as shareholder. It pays 19% corporate tax on the first €200,000 of profit and 25.8% above that. Dividends to a parent company in a treaty country usually go out without Dutch dividend tax. Later, the same company holds the marketing authorisation: read selling medicines in Europe.

Based on Regulation (EU) 536/2014 (Clinical Trials Regulation), Regulation (EU) 2017/745 (MDR), the Dutch Medical Research Involving Human Subjects Act (WMO) and the CCMO guidance, as applied in September 2026. Trial files are prepared by specialised partners; Holdwise coordinates.

Who does what

Holdwise sets up and runs the Dutch company and stays your single point of contact. Specialist partners do the licence and product work. You keep one contact, one file and one invoice.

You

Your company

  • Own the protocol, the product and the data
  • Choose the countries, the sites and the CRO
  • Provide the investigational product and the manufacturer documents
  • Sign the power of attorney; nobody travels
Holdwise

The Dutch base

  • Sets up the Dutch company (a BV), by power of attorney, with the notary
  • Registered office, KVK number, tax number and VAT number
  • Bank account and bookkeeping for trial payments to sites and vendors
  • Annual accounts, corporate tax return, substance in the Netherlands
  • Single point of contact for the CRO, the insurer and the importer
Specialist partner, via Holdwise

Licences and product rules

  • The CTIS application and the ethics committee file
  • Trial monitoring, pharmacovigilance during the trial, data management
  • Trial insurance under the Dutch decree
  • Import and qualified person release of the investigational product
  • Clinical trial agreements with hospitals, in Dutch and English

The route, step by step

What happens from your first question to the day your first product is on the European market.

  1. One question. You tell us what the product is, the phase of the trial, the countries and whether you have a CRO. We answer in writing with the structure that fits and one written proposal.
  2. The Dutch company. The notary sets up the BV by power of attorney with the parent as shareholder. You receive the KVK number, the tax number and the VAT number. The bank file starts on day one.
  3. The role. Your Dutch company becomes the legal representative. The partner drafts the sponsor delegation, the insurance and the agreements with the sites.
  4. The application. The CRO or regulatory partner files the trial in CTIS with the Dutch company as legal representative. The CCMO and the ethics committee review.
  5. The product. The investigational medicine is imported and released in the EU by a licensed importer and a qualified person, or made in the EU.
  6. After the trial. The same company applies for the marketing authorisation, holds it and sells the product. Nothing has to be moved to another entity.

Common questions

Is the legal representative liable for the trial? +
The representative is responsible for making sure the sponsor meets its obligations under the regulation, and it is the address for the authorities. The liability towards participants is covered by the trial insurance that the sponsor must have. In practice the sponsor and the representative set out their duties and liabilities in a written agreement.
Can a CRO be the legal representative and also run the trial? +
Yes, and many CROs offer exactly that. The alternative is your own Dutch company as legal representative with the CRO as the service provider. That keeps the contracts, the insurance and the later product rights in your group.
Do I need the legal representative before the application? +
Yes. The representative is named in the application in CTIS. Set up the Dutch company and sign the delegation before the CRO files.
What if the trial takes place only in the Netherlands? +
For a trial in one country the regulation lets that country accept a contact person in place of a legal representative. Whether the Netherlands applies that option to your trial is checked with the CCMO before you file. For a trial in two or more EU countries the legal representative is always required.
Does Holdwise run the trial? +
Holdwise sets up and runs the Dutch company and coordinates the partners. The trial itself, the CTIS file, the monitoring and the insurance are done by clinical research and regulatory specialists. You keep one contact: us.
What does the Dutch company cost? +
The setup starts from €2,950 excluding VAT, notary included. Running it means a registered address, bookkeeping, the annual accounts and the corporate tax return. We put the whole amount in one written proposal before you decide.

Ask about your own situation

Tell us what you make or sell, where your company is and which countries you want to sell in. You get a written answer. Where a Dutch company fits, we write down what it would look like and what it costs.

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Why founders choose the Netherlands

Three practical reasons. First: your money stays available. The Netherlands lets an importing company pay import VAT on its tax return instead of at the border (the Article 23 licence). You can put that money into stock straight away. Neighbouring countries offer this in a far more limited form.

Second: profit passes freely between the companies in your structure. Profit from your operating company can go to your holding company free of tax (the participation exemption). Dividends to many foreign parent companies are paid with 0% withholding tax under treaty rules. The first €200,000 of profit is taxed at 19%.

Third: you can do everything from abroad, in English. Incorporation takes two to three weeks, with video identification or a power of attorney. The tax authority works digitally, and every document you need is available in English. You never have to board a plane to own and run a Dutch company.

See how this applies to your situation

Holdwise Adviseur
Knowledge on doing business in the Netherlands · based on the 2026 figures