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Which risks did regulators probe for approved gene therapies?

From the FDA and EMA reviews of all 26 approved gene therapies. Each answer links to the regulator's own sentence.

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Short answer
What reviewers probed for each of the 26 approved gene therapies.

Precedent by precedent

26 approved gene therapies, with the reviewers' own words.

Adstiladrin

nadofaragene firadenovec · IFN-alpha2b (adenovirus, intravesical)
Immune & cytokine safety
Neutralizing anti-adenovirus and anti-IFNa2b antibodies in most high-dose monkeys, persisting through observation period
“Development of neutralizing antibodies to the adenovirus and anti-IFNα2b antibodies occurred in the majority of animals in the high dose group and to a lesser extent in the low dose group”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Biodistribution & persistence
Vector DNA in bladder (Days 8, 98); blood within 24 h; urine 2-3 days; low levels in liver, kidney, gonads; none in reproductive tissue at end
“Biodistribution analysis indicated the presence of rAd-IFN DNA in the bladder on Days 8 and 98.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Beqvez

fidanacogene elaparvovec · Factor IX
Immune & cytokine safety
Anti-hFIX and anti-capsid antibodies in most NHPs, rising over time, correlated with declining hFIX
“The levels of both anti-hFIX and anti-AAV antibodies increased with time, which correlated with a decline in plasma hFIX protein levels.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗
Biodistribution & persistence
Vector in all NHP tissues incl. brain/testes; highest liver, spleen, lymph nodes; liver to day 542; rabbit semen to 4 months
“The highest vector DNA concentrations were detected in the liver, spleen, and inguinal lymph nodes.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Casgevy

exagamglogene autotemcel · BCL11A enhancer (CRISPR-Cas9, ex vivo HSC)
Immune & cytokine safety
In vitro innate immune (type I IFN) assay showed no activation, but FDA deemed it uninterpretable (positive control failed)
“The study results were uninterpretable since the positive control group of R848 CD34+ cells did not show high levels of expression of IFIT1, TIG1, OAS1, and IL-6 transcripts, which were observed in R848 PBMC cohort.”
✓ VerifiedFDA pharmacology/toxicology review, p. 35Source ↗
Biodistribution & persistence
Human DNA highest in bone marrow, then spleen, blood, lung, liver, kidney; minimal in gonads; stable ~87% editing at 20 weeks
“Human DNA was detected in most of the examined tissues in mice that received a single IV administration of 1 x 106 cells/mouse, with the highest levels detected in the bone marrow, followed by spleen, blood, lung, liver, and kidney.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Elevidys

delandistrogene moxeparvovec · Micro-dystrophin
Immune & cytokine safety
Anti-AAV antibodies in mice; NHP: capsid/transgene T-cell responses, liver enzymes, anaphylaxis on redosing with rituximab/sirolimus
“increased antibody titers against AAVrh74 vector capsid from Weeks 5 to 12, increased cellular immune response against AAVrh74 vector capsid and micro-dystrophin at Week 2 compared to baseline”
✓ VerifiedFDA pharmacology/toxicology review, p. 30Source ↗
Biodistribution & persistence
Systemic; highest in liver, then adrenal, aorta, heart, muscle; low in testes; shedding in urine/feces/plasma cleared by Day 44
“Systemic ELEVIDYS distribution was observed, with the highest vector levels in the liver, followed by the adrenal gland, aorta, heart, muscle, and esophagus.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Fayuvi

rebisufligene etisparvovec · SGSH (AAV9)
Immune & cytokine safety
Immunogenicity greater against AAV9 capsid than hSGSH transgene, proportional to dose
“Vector immunogenicity was greater against the AAV9 capsid versus the hSGSH transgene and was proportional to vector dose level.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗
Biodistribution & persistence
Highest in liver; lower in brain; no vector-related gross or histopathologic findings
“Vector BD in brain was less than that of liver (highest) across dosed groups.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗

Genglycos

pariglasgene brecaparvovec · G6PC (AAV8)
Immune & cytokine safety
Anti-AAV8 nAbs in all dosed mice and NHPs; AAV8 T-cell responses in mice; sporadic cytokine elevations; juvenile immune stimulation
“T-cell responses to the AAV8 peptide pool were observed in 2/10 mice on Day 29 and in 6/10 mice on Day 92.”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗
Biodistribution & persistence
Highest in liver; vector DNA in all tissues incl. gonads (DNA and RNA); clearance from blood ~24 weeks in patients
“DTX401 biodistribution (BD) was highest in the liver and vector DNA was detected in all evaluated tissues, including the ovaries and testes”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Glybera

alipogene tiparvovec · LPL (AAV1)
Immune & cytokine safety
Neutralising anti-AAV1 capsid antibodies blocked readministration; no CD8+ T cells in infiltrates; no anti-LPL antibodies
“on readministration, the second dose was not able to elicit a response, an effect attributable to formation of neutralising antibodies to AAV1 capsid.”
✓ VerifiedEMA assessment report, p. 25Source ↗
Biodistribution & persistence
Injected muscle, liver, spleen, inguinal lymph nodes; gonads/semen positive; incomplete clearance by 180 days in mice
“The main tissues where vector DNA was detected were the injected muscle, liver, spleen and inguinal lymph nodes.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Hemgenix

etranacogene dezaparvovec · Factor IX
Immune & cytokine safety
Anti-AAV5 capsid IgG persisting 6 months; anti-hFIX antibodies in 5/12 NHPs reducing FIX levels
“Antigenicity endpoints were included in single dose toxicity studies, capsid antigens generally caused high titres of anti AAV5 antibodies. In addition, anti-human FIX antibodies were observed inconsistently in NHP.”
✓ VerifiedEMA assessment report, p. 33Source ↗
Biodistribution & persistence
Liver highest, then adrenal, spinal cord; vector in testis/epididymis/semen at 26 wks; saliva/urine clear by ~week 8-12
“Vector DNA was also identified in the adrenal glands and spinal cord, followed by limited vector presence in various tissue types.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗

Imlygic

talimogene laherparepvec · GM-CSF (oncolytic HSV-1)
Immune & cytokine safety
Lethal disseminated HSV infection in immunodeficient mice (up to 20% nude, 100% SCID); immunocompetent mice tolerated doses
“Lethal systemic viral infection was observed in up to 20% of nude mice (primarily deficient in T lymphocyte function) and 100% of SCID mice (devoid of both T and B lymphocytes).”
✓ VerifiedEMA assessment report, p. 45Source ↗
Biodistribution & persistence
Low-level viral DNA at injection site, blood and urine 24 h after 5th SC dose in mice; cleared by later timepoints
“Viral DNA was detected at low levels in the injection site, blood and urine at 24 hours following the administration of the 5th injection of the product.”
✓ VerifiedFDA pharmacology/toxicology review, p. 74Source ↗

Itvisma

onasemnogene abeparvovec (intrathecal) · SMN1 (AAV9, intrathecal)
Immune & cytokine safety
Mononuclear cell inflammation in NHP neural tissue; clinically all patients developed high anti-AAV9 titers, anti-SMN in ~7%
“Anti-AAV9 antibody responses were consistent and robust across all studies, with all participants developing high titers that remained elevated through study completion.”
✓ VerifiedFDA summary basis for approval, p. 17Source ↗
Biodistribution & persistence
Highest in liver, DRG, spinal cord; lower peripheral incl. gonads; clinical shedding mainly fecal, >90% within 2 weeks
“Biodistribution (BD) of OAV101 demonstrated the highest titers in the liver, DRG, and spinal cord, with lower levels reported in the periphery, including gonads.”
✓ VerifiedFDA summary basis for approval, p. 16Source ↗

Kebilidi

eladocagene exuparvovec · AADC
Immune & cytokine safety
Dose-dependent anti-AAV2 capsid ADA in rats; no effect on biodistribution or expression; anti-AADC not assessed
“The formation of anti-drug antibodies against the AAV2 vector capsid was dose dependent with the highest incidence observed in Group 4 high-dose animals at Days 30 and 180.”
✓ VerifiedEMA assessment report, p. 40Source ↗
Biodistribution & persistence
Mostly CNS, highest in putamen; vector persists to D180 with decline; no blood/CSF shedding in rat
“Persistence of vector DNA was most notable in the putamen, cerebrum, cerebellum, and spinal cord at all time points, with the highest levels in the putamen.”
✓ VerifiedFDA summary basis for approval, p. 11Source ↗

Lenmeldy

atidarsagene autotemcel · ARSA (LVV, ex vivo HSC)
Immune & cytokine safety
No anti-ARSA antibodies or adverse neurobehavioral effects in mice; anti-ARSA antibodies in 15% of patients clinically
“No development of anti-ARSA antibodies or adverse neurobehavioral effects were observed in As2-/- mice transplanted with ARSA LVV-transduced mHSPCs.”
✓ VerifiedFDA summary basis for approval, p. 15Source ↗
Biodistribution & persistence
Engrafts BM, spleen, thymus, liver; lower levels in brain; integrated LVV persists stably; shedding risk low
“In addition to the bone marrow, spleen, thymus, and liver, transduced human cells were also detected at lower levels in the mouse brain, demonstrating migration of the transduced cells into target organs.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Luxturna

voretigene neparvovec · RPE65
Immune & cytokine safety
Anti-AAV2 capsid antibodies (dogs, pre-exposed NHPs); minimal T-cell responses; mild ocular inflammation on re-administration
“There were no pro-inflammatory T cell responses (IFN-γ) to the AAV2 capsid, except for one NHP previously exposed to AAV2 vector that developed a CD4+ T cell response.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗
Biodistribution & persistence
Vector DNA mainly in intraocular fluids; low in optic nerve, spleen, liver; none in gonads; shedding not studied in animals
“The highest levels of vector DNA were detected primarily in the intraocular fluids (anterior chamber fluid and vitreous) of vector-injected eyes.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Otarmeni

lunsotogene parvec · OTOF (AAV, intracochlear)
Immune & cytokine safety
All monkeys anti-AAV1 NAb positive by week 27, no anti-otoferlin antibodies; NAbs not associated with safety signal; minimal cochlear infiltrates
“There were no serum or CSF samples positive for anti-otoferlin antibodies at any time point.”
✓ VerifiedFDA pharmacology/toxicology review, p. 25Source ↗
Biodistribution & persistence
Cochlear retention through 27 weeks; transient plasma/CSF; low neural off-target expression; none in gonads; shedding only Day 2
“Viral shedding was detected in multiple samples (buccal swabs, nasal swabs, feces, and urine) on Day 2 post-administration in monkeys but was absent by 7 weeks, indicating clearance from excretory pathways.”
✓ VerifiedFDA pharmacology/toxicology review, p. 16Source ↗

Papzimeos

zopapogene imadenovec · HPV6/11 antigens (gorilla adenovirus)
Immune & cytokine safety
Intended HPV-specific CD8+ T-cell IFN-gamma/TNF-alpha responses; in silico screen shows low off-target human protein reactivity
“The only protein sequences with alignment to the PRGN-2012 fusion antigen were proteins expressed by HPV, indicating there is a low potential for off-target human protein reactivity.”
✓ VerifiedFDA pharmacology/toxicology review, p. 4Source ↗
Biodistribution & persistence
No biodistribution/shedding studies; mice unreliable for adenoviral shedding; clinical shedding study as postmarketing commitment
“Shedding analyses were not required for nonclinical studies for this product as mice are generally an unreliable species for adenoviral shedding studies to compare to human shedding.”
✓ VerifiedFDA pharmacology/toxicology review, p. 11Source ↗

Roctavian

valoctocogene roxaparvovec · Factor VIII
Immune & cytokine safety
Anti-AAV5 antibodies in all species; anti-hFVIII antibodies cross-reacting with murine FVIII caused bleeding phenotype (species-specific)
“These anti-hFVIII antibodies cross-reacted with the murine endogenous FVIII, leading to a loss of endogenous FVIII activity, a bleeding phenotype, and subsequent visceral lesions (in heart, lungs and epididymis) associated with haemorrhages.”
✓ VerifiedEMA assessment report, p. 31Source ↗
Biodistribution & persistence
Liver highest, then lung, heart, lymph nodes, kidney, spleen, marrow, testis, brain; mRNA mainly liver; NHP brain <1% of liver
“Following IV administration of 2.13 × 1014 vg/kg ROCTAVIAN, the highest vector DNA concentration was detected in the liver, followed by the lung, heart, lymph nodes, kidney, spleen, bone marrow, testis, and brain through 6 months post-administration.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗

Tudriqev

vusolimogene oderparepvec · GALV-GP + GM-CSF (oncolytic HSV-1)
Immune & cytokine safety
No test-article-related adverse findings in tumor-bearing mice; RNAseq showed immune infiltration/inflammation genes in injected tumors
“showed increased expression of genes associated with immune cell infiltration and inflammation in injected tumors compared to non-injected tumors”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗
Biodistribution & persistence
Viral genomes mainly at injection site; mRP1 DNA in blood, organs, ovaries, neural tissue in rats to Day 71; no latency/reactivation at 6 months
“viral genomes were predominantly present at the injection sites (i.e., tumor), irrespective of the route of administration.”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗

Vyjuvek

beremagene geperpavec · COL7A1 (HSV-1, topical)
Immune & cytokine safety
Minimal to slight lymphoid hyperplasia in spleen and lymph nodes consistent with inflammatory response to vector
“microscopic findings of minimal to slight lymphocyte follicular hyperplasia in the spleen and minimal to slight lymphocyte hyperplasia in the axillary and/or inguinal lymph nodes were consistent with an inflammatory response to KB103”
✓ VerifiedEMA assessment report, p. 30Source ↗
Biodistribution & persistence
Vector mainly at application/injection site, declining to baseline by 30 days after last dose; not detected in other tissues after topical dosing
“resulted in vector detection primarily at the injection site, which declined to baseline by 30 days after the last dose.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Waskyra

etuvetidigene autotemcel · WAS (LVV, ex vivo HSC)
Immune & cytokine safety
No dedicated immunotox studies; no anti-WASP antibodies in 27 treated patients
“No anti-WASP antibodies have been detected in any of the 27 participants treated with WASKYRA”
✓ VerifiedFDA summary basis for approval, p. 14Source ↗
Biodistribution & persistence
Distribution limited to hematopoietic tissues; no vector in brain or testes, no bystander transduction or germline transmission
“No human or LVV sequences were detected in non-hematopoietic tissues (brain and testes)”
✓ VerifiedEMA assessment report, p. 33Source ↗

Zevaskyn

prademagene zamikeracel · COL7A1 (RV-modified keratinocyte sheets)
Immune & cytokine safety
Clinical only: transient anti-Col7 antibodies in 2/7 Phase 1/2a subjects; no systemic immune responses in Phase 3
“In the Phase 1/2a study, circulating anti-Col7 antibodies were detected in two out of seven subjects, which resolved without intervention by 1 year after treatment.”
✓ VerifiedFDA summary basis for approval, p. 13Source ↗
Biodistribution & persistence
COL7A1 transgene DNA confined to explanted product at 4 and 8 weeks; below detection in all other tissues
“COL7A1 transgene DNA was detected in explanted nonclinical products at both sacrifice time points.”
✓ VerifiedFDA summary basis for approval, p. 12Source ↗

Zolgensma

onasemnogene abeparvovec · SMN1
Immune & cytokine safety
Systemic inflammatory response in mice; capsid/transgene immunity proposed for atrial thrombosis; NHP antibodies to vector and transgene
“Nevertheless, the NHP raised an antibody titre against both the vector and the transgene, while the mice raised an antibody titre against the vector alone.”
✓ VerifiedEMA assessment report, p. 35Source ↗
Biodistribution & persistence
Highest in heart, then lung, liver, lumbar spinal cord, muscle, brain; low in spleen and gonads through 12 weeks
“The biodistribution (BD) and SMN transgene expression profile of AVXS-101 were evaluated in neonatal FVB mice through 12 weeks.”
✓ VerifiedFDA pharmacology/toxicology review, p. 2Source ↗

Zynteglo

betibeglogene autotemcel · HBB T87Q (LVV, ex vivo HSC)
Immune & cytokine safety
No immunotoxicity studies; immunogenicity of beta-A-T87Q-globin not anticipated; patients immunosuppressed by busulfan
“No immunotoxicity studies have been performed since immunogenicity with βA-T87Q-globin is not anticipated.”
✓ VerifiedEMA assessment report, p. 38Source ↗
Biodistribution & persistence
Traditional ADME/PK not done; distribution assessed by VCN in bone marrow and blood of engrafted cells
“Cell distribution was assessed by the applicant in the target tissues, BM, and peripheral blood, by VCN measurements.”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗

Kresladi

marnetegragene autotemcel · ITGB2 (LVV, ex vivo HSC)
Immune & cytokine safety
Not stated in public reviews
Biodistribution & persistence
VCN in hematopoietic organs; undetectable/low in non-hematopoietic organs and gonads; serum p24 negative (no RCL)
“Hematopoietic reconstitution was observed in the peripheral blood (PB) and BM and measurable VCN was detected in other hematopoietic organs, whereas undetectable or low VCN was observed in non-hematopoietic organs including the gonads.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Lyfgenia

lovotibeglogene autotemcel · HBB T87Q (LVV, ex vivo HSC)
Immune & cytokine safety
Not stated in public reviews
Biodistribution & persistence
No traditional PK; cell distribution assessed by VCN in bone marrow and peripheral blood
“Cell distribution was assessed by the applicant in the target tissues, BM, and peripheral blood, by VCN measurements.”
✓ VerifiedFDA pharmacology/toxicology review, p. 16Source ↗

Skysona

elivaldogene autotemcel · ABCD1 (LVV, ex vivo HSC)
Immune & cytokine safety
Not stated in public reviews
Biodistribution & persistence
Human and vector sequences in all tissues tested through 3 months; highest in bone marrow, then lung, liver, spleen; lowest in brain, intestine, muscle
“the highest concentration (copies/µg) was observed in bone-marrow were signals above the upper LoQ were observed.”
✓ VerifiedEMA assessment report, p. 31Source ↗

Strimvelis

autologous CD34+ cells transduced with ADA (no INN) · ADA (gamma-retroviral, ex vivo HSC)
Immune & cytokine safety
Not stated in public reviews
Biodistribution & persistence
Engraftment in BM, spleen, thymus, blood; low human DNA/RV in non-target organs and gonads (residual blood); no non-target transduction
“Biodistribution analysis did not show any evidence of transduction of non-target cells: vector DNA was only detected in the presence of donor cells.”
✓ VerifiedEMA assessment report, p. 24Source ↗