07
Investor Readiness Structural · 3–5 yr

Uneven Clinical Trials

Three routes out of a five-regulator patchwork

LATAM has no central regulator: review times run from 70 business days at Argentina’s ANMAT to 18–24 months at Brazil’s ANVISA. Choose a route early, global-first, parallel jurisdiction, or reliance.

The rationale

LATAM has no centralized agency overseeing trial phases or market readiness, so every country is its own project. As reported in 2025: Argentina’s ANMAT clears in 70 business days or fewer, down from roughly 160 since 2017; Chile’s ISP takes 6 to 8 months; Colombia’s INVIMA 12 to 18 months; Brazil’s ANVISA historically 18 to 24 months; Mexico’s COFEPRIS is officially 5 to 60 days on the equivalence route, yet backlogs push real approvals to one or two years. Each is a live regulatory fact and each has probably moved since the interviews. A venture compliant in one country is not a regional venture, and investors price the difference.

The report sets out three non-exclusive routes. Global-first alignment means building to FDA or EMA-grade standards from the first protocol, which de-risks export and capital access; that is a founder decision available this year and needs no institutional reform. Parallel jurisdictions, special economic zones with bespoke regulatory pathways, compress permit cycles, and the region already runs large ones with real economic records in Costa Rica, the Dominican Republic and Uruguay. Regional interoperability means reliance: mutual recognition of selected scientific approvals, built on machinery that already exists in health, the Pan American regulatory network and the single-audit program for medical devices.

Two objections deserve a straight answer. Stakeholders cautioned that an FDA-only posture can backfire, slowing iteration velocity, entrenching incumbent advantages and loading prohibitive compliance costs onto pre-revenue teams, so global-first belongs where the export path pays for it and not as a reflex. And the biomedical SEZ case the report examines, Próspera in Honduras, is contested by bioethicists, challenged as illegal by Honduran authorities, and in litigation as the state moves to unwind the framework. Its self-reported speed claims cannot be verified and are not used here.

The evidence

≤70 business days Argentina’s ANMAT review time, cut from roughly 160 business days since 2017, as reported in 2025 Cristián Hernández Cuevas (Zentynel), 2025
18–24 months Brazil’s ANVISA historical review time for innovative therapies, against a reform target of 120 to 365 days Cristián Hernández Cuevas (Zentynel), 2025
61% Share of LATAM deep tech companies in biotechnology by 2023, the population directly exposed to trial and approval regimes, reproduced by EMERGE’s 2025 census Inter-American Development Bank (IDB Lab), 2023

What it unlocks

One dossier more than one LATAM regulator will accept, so a biotech can reach a regional market without repeating the same review five times.

It has been done before

The Medical Device Single Audit Program

Running since its 2014 pilot, MDSAP lets one quality-system audit by an accredited auditing organization satisfy five regulators at once: the US FDA, Health Canada, Brazil’s ANVISA, Australia’s TGA and Japan’s MHLW. Health Canada has required it since 2019, and ANVISA accepts the audit report as the basis for the Brazilian GMP certificate needed to register class III and class IV devices. Recognition works without a supranational authority, and the region’s largest regulator is already inside it.

US Food and Drug Administration, 2014

First moves

  1. 0–6 months

    Publish a dated five-country regulatory clock

    Compile review times, dossier requirements and foreign-data acceptance rules for ANVISA, COFEPRIS, INVIMA, ISP and ANMAT, each entry stamped with the date it was last checked with the agency, and refresh it quarterly.

    LADP coalition secretariat + national regulatory affairs associations
  2. 6–18 months

    Run a reliance pilot on one product class

    Pick one low-risk class, in-vitro diagnostics is the obvious candidate, and get two agencies to accept each other’s dossier review under a written reliance protocol with a defined re-review and appeal route.

    National regulators (ANVISA, ISP, INVIMA) + PAHO
  3. 18–36 months

    Extend single-audit recognition beyond devices

    Use the medical-device single-audit model as the template for a second product class, and map in-zone conformity assessment in existing free zones to US, EU and ISO standards so results travel outside the zone.

    Mercosur and Pacific Alliance secretariats + free-zone authorities (CINDE, CNZFE, Uruguay XXI)

How we would know it worked

  • Median days from dossier submission to decision at each of the five agencies, published quarterly in the regulatory clock, with the spread between fastest and slowest narrowing.
  • Product classes covered by a signed reliance or mutual-recognition protocol between two or more LATAM regulators, rising from zero.
  • Approvals granted on the basis of another agency’s review, reported annually by each participating regulator.
  • Share of LATAM biotech ventures closing a Series A that hold an FDA or EMA-grade dossier at the time of the round, tracked through the funders registry.

What could go wrong

Reliance read as a loss of sovereignty

Accepting another agency’s review looks, to a health ministry, like outsourcing a public-safety function, and one adverse event inside a pilot can end the whole program. Containment: start with a single low-risk product class, preserve the national agency’s power to refuse and to re-review, and publish the safety record of every reliance decision.

Special jurisdictions used as a compliance escape hatch

SEZ routes for biomedical work attract ventures that could not clear a national regulator, and Próspera shows how quickly that becomes a legal and reputational liability for everyone associated with it. Containment: restrict special-jurisdiction pathways to manufacturing, conformity assessment and non-human testing, and require every human trial to run under the ordinary national ethics and regulatory framework.

Who acts

FoundersPolicymakersInvestors

Rests on

08 Regulatory Portability 33 countries, one optional 34th regime

11 Anchor Public R&D Public R&D budgets on an infrastructure footing

05 Global Mindset Language first, structure next

The data behind it

LATAM deep tech by sector
share of ventures
Biotechnology61%
Artificial Intelligence11%
Nanotechnology6%
Cleantech5%
Spacetech4%
Advanced Mobility4%
Robotics2%
Advanced Manufacturing2%
Healthtech2%
Advanced Materials1%
Medical Devices & Others1%

Biotechnology and AI alone account for 72% of mapped ventures, a reflection of the region’s biological-sciences talent and biodiversity.

As originally publishedAs of 2023Report p.30

Re-checked against a current source. Unchanged from the published report. (EMERGE (Emerge Brasil) & Cubo Itaú)

SourcesInter-American Development Bank (IDB Lab), Deep Tech: The New Wave; EMERGE (Emerge Brasil) & Cubo Itaú, Radar Deep Tech LATAM 2025

  • The report prints "<1%"; charted at its upper bound. Named sectors sum to 99%.

Methodology: IDB 2023 sector split by COMPANY COUNT, CONFIRMED still current by EMERGE Radar 2025 (biotech 61% / AI 11% both editions). But it measures the stock, not the flow: see the new `aiMomentum` dataset, AI is 11% of companies yet ~70% of rounds by 2023–2025 vintage. Pair the two on the site (ledger #42).