ValGenesis Blog

Audit Pressure? Stop Last-Minute Scrambles  With AI-Powered CQV

Written by Sweta Shah | Aug 21, 2025 1:00:00 PM

Audit readiness comes from how you run commissioning, qualification and validation (CQV) every day. With a risk-based approach, you focus effort on the activities that most affect patient and product quality. A digital approach captures records as the work happens in validated systems with role-based access, timestamps, and audit trails.

Together, these practices shorten preparation. When you author a protocol, you can reuse approved content that is linked to risk. Execution then guides the right steps and ties evidence to the requirement it supports. Quality reviews shift to review by exception, so you spend time on what matters. And when an inspection notice arrives, you retrieve requirement-to-evidence traceability in minutes from your validated system of record because entries are captured and organized at the point of work.

 

Why Last-Minute Scrambles Happen

Gaps often appear where intended use meets documented evidence. You may have assessed risk and completed testing, but the rationale for what was tested — and why it was sufficient — is scattered across tools. ICH’s Q9(R1) guidance (2023) tightened expectations around risk identification, communication, and decision-making. For software used in production and quality systems, the FDA’s draft Computer Software Assurance for Production and Quality System Software (FDA, 2022) recommends scaling assurance activities to risk and using critical thinking to select scripted, unscripted, exploratory, or automated testing because it fits the risk, not simply because "we always do it that way." This approach reduces documentation volume without reducing confidence.

 

An AI-Enabled CQV Workflow

In an AI-enabled CQV workflow, authoring shifts to controlled reuse, ensuring consistency, compliance, and efficiency across projects. 

An AI-powered digital assistant assembles a protocol from approved content, design inputs, and risk rationales. Subject matter experts (SMEs) refine the draft and e-sign. Execution is guided — the system prevents skipped steps, checks ranges in real time, and attaches evidence to the exact requirement. 

This end-to-end approach means the record builds as you work, so nothing needs to be reconstructed later. It aligns with Annex 11 of EU GMP (European Commission, 2011), Part 11 of 21 CFR (eCFR, n.d.), and risk-based assurance under CSA and GAMP 5 (ISPE, 2022).

 

Governance That Makes AI Audit-Ready

Regulators are setting clear expectations for AI. Draft guidance (FDA,2025) outlines how to establish credibility through pre-use planning, transparency, performance monitoring, and change control. CDER’s discussion paper (FDA/CDR, 2023) provides the risk-based context for using AI in drug manufacturing. Industry guidance translates these expectations into practical governance patterns for AI-enabled computerized systems (ISPE, 2025; ISPE, 2022).  

In practice, treat each AI-assisted function — such as protocol drafting or anomaly detection — as a controlled part of your validation quality system. Start by defining intended use and risk, then document the datasets, their boundaries, and the acceptance criteria (ISPE, 2025). Verify that the function meets those criteria and release it with SME approval (ISPE, 2022). Continue monitoring for performance drift and manage any model update through formal change control (FDA/CDER, 2023; ISPE, 2025).

 

Part 11/Annex 11 Control Map — Built Into the Flow

To stay compliant with Annex 11 and Part 11, your systems must meet a few baseline controls that should be part of your daily operations:

  • Role-based access with unique, attributable user IDs.
  • Time-stamped, immutable audit trails for creation, modification, and deletion; periodic audit-trail review defined in SOPs.
  • Secure, linked e-signatures that establish the record’s purpose and verify the signer’s intent.
  • Validated state with periodic review and documented change control.

These are baseline requirements. Embed them into daily operations so the inspection-ready evidence is the record itself — not a last-minute slide deck.

 

Proof It Works

Across the industry, the shift from paper-heavy validation to data-centric CQV, paired with review by exception and real-time methods, has shortened review cycles and made audit readiness more routine.  

ISPE’s Facility of the Year Awards (FOYA) recognize innovation and operational excellence in pharma and biopharma manufacturing. Winners provide credible, recent examples of current benchmarks for compliant performance. One site fully integrated its manufacturing execution system (MES) with quality systems, resulting in faster batch reviews and fewer deviations (ISPE, 2025). Another site adopted real-time release, surfacing issues earlier and reducing reliance on extended review periods (ISPE, 2022). 

Guidance is evolving to keep pace. The ISPE Good Practice Guide: Digital Validation (ISPE, 2025) explains how digital validation tools enhance audit readiness, strengthen data integrity by design, and streamline execution and reporting.  

Validation 4.0 applies Pharma 4.0™ principles to the validation lifecycle — emphasizing digitalization, automation, and data integrity by design so verification relies on data captured at the point of work.  Case studies under this framework show how data-driven, in-process controls can replace slow, error-prone sampling with faster verification cycles while maintaining full compliance (ISPE, 2022).

 

From Weeks to Minutes: A Simple Pattern

Think of the shift as changing the daily rhythm, not adding more steps. In the first week, you agree on the intended use and risk for the system, capturing that rationale once in your validation workspace. By week two, your team has a small library of approved content requirements, test intent, and acceptance notes that the digital assistant can reuse. 

Authoring no longer feels like a blank page. You open a new protocol, the AI assistant proposes a draft from the library, and you adjust a few fields before routing for e-signature. Execution is straightforward: operators see exactly what to do, out-of-range entries are flagged at the point of work, and the record builds itself as the task progresses. 

To keep inspection ready, stay on track with brief rationale notes and routine audit-trail reviews. When an inspection notice arrives, you simply open the system, filter by lot or change, and review step by step. The evidence is already captured as you work and sits where it needs to be. 

 

Practice Like the Real Thing

Short, regular practice makes audit readiness routine. Quick drills show that your validated system of record and your team can pull requirement-to-evidence traceability in minutes, not weeks. Use the steps below to rehearse what you’ll do during an inspection. 

  1. Review your records in the same format the FDA uses for Form 483 observations. This helps you spot and address issues before inspectors do.

  2. Run retrieval drills by requirement, by system, and by specific change items. This ensures your team can demonstrate end-to-end traceability on demand.

  3. Keep short rationale notes. For each risk assessment or testing choice, record a brief “why this approach” explanation. These quick notes often resolve inspector questions faster than searching through full documents. 

When you practice retrieval and first-pass review on a cadence, audit readiness becomes part of everyday CQV — not a special project. You reduce disruption, shorten release timelines, and walk into inspections with confidence because the evidence is already organized and defensible.

Want to learn more? Watch the webinar below.

 

 

 

References

eCFR. (n.d.). 21 CFR Part 11—Electronic records; electronic signatures. Retrieved [Month Day, Year], from https://www.ecfr.gov

European Commission. (2011). EU-GMP Annex 11: Computerised systems. Public Health.

FDA. (2022). Computer software assurance for production and quality system software. U.S. Food and Drug Administration.

FDA. (2025). Considerations for the use of artificial intelligence to support regulatory decision-making for drug and biological products. U.S. Food and Drug Administration.

FDA/CDER. (2023). Artificial intelligence in drug manufacturing (Discussion paper). U.S. Food and Drug Administration.

ICH. (2023). Q9(R1) quality risk management (Step 4). ICH Database.

ISPE. (2022). GAMP® 5 guide (2nd ed.). ISPE.

ISPE. (2022). Meet the 2022 FOYA supply chain category winner: Takeda (parametric/real-time release). ISPE.

ISPE. (2022). Validation 4.0: Case studies for oral solid dose manufacturing. Pharmaceutical Engineering, Sept–Oct 2022. ISPE.

ISPE. (2025). 2025 FOYA category winner—Pharma 4.0™ (CSL Behring): MES–QMS integration reduced batch review time and deviations. ISPE.

ISPE. (2025). GAMP® guide: Artificial intelligence. ISPE.

ISPE. (2025). Good practice guide: Digital validation. ISPE.

U.S. Food and Drug Administration. (n.d.). Inspectional observations and citations (Form FDA 483 resources and dashboards). Retrieved [Month Day, Year], from https://www.fda.gov