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Which risks did regulators probe for approved ADCs?

From the FDA and EMA reviews of all 14 approved ADCs. Each answer links to the regulator's own sentence.

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Short answer
What reviewers probed for each of the 14 approved ADCs.

Precedent by precedent

14 approved ADCs, with the reviewers' own words.

Adcetris

brentuximab vedotin · CD30
Immune & cytokine safety
Anti-drug antibodies (PAHA) in monkeys reduced ADC exposure but increased MMAE exposure without added toxicity
“The positive immunogenic responses in monkeys appeared to reduce the concentrations of brentuximab vedotin and TAb after multiple doses, and conversely increased the concentrations of MMAE after multiple doses in of the animals with high anti-brentuximab antibody (PAHA) levels.”
✓ VerifiedEMA assessment report, p. 39Source ↗
Biodistribution & persistence
Low Vss for ADC; free MMAE widely distributed (pituitary, adrenal, thyroid, lung, kidney, liver), biliary/fecal excretion; placental transfer
“MMAE was mainly distributed to pituitary gland, adrenal gland, thyroid, lung, kidney, liver and subsequently bile and intestine.”
✓ VerifiedEMA assessment report, p. 26Source ↗

Besponsa

inotuzumab ozogamicin · CD22
Immune & cytokine safety
Low ADA incidence in rats (10-13%); no ADA detected in monkeys
“In the 4- and 26-week repeat-dose toxicity studies in monkeys, ADA was not detected in any animals after administration of inotuzumab ozogamicin or the G544 antibody.”
✓ VerifiedEMA assessment report, p. 39Source ↗
Biodistribution & persistence
Limited tissue distribution in rat (tissue:plasma <=0.6; liver highest), minimal brain penetration, longer tissue retention
“Distribution of [3H]inotuzumab ozogamicin radioequivalents into tissues was limited, with tissue-to-plasma AUCinf ratios ≤0.6 for all tissues evaluated.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Datroway

datopotamab deruxtecan · Trop-2
Immune & cytokine safety
ADA in 5/6 monkeys at 10 mg/kg reducing exposure; minimal in vitro cytokine release; transient CRP increases
“Five of 6 monkeys given 10 mg/kg showed ADA positive responses after the 3-month dosing period, and there was a reduction in Dato-DXd exposure after the 4th dose compared to the 1st dose.”
✓ VerifiedFDA multi-discipline review, p. 66Source ↗
Biodistribution & persistence
14C-DXd rapid wide distribution without retention (highest intestine, bladder, kidney); low DXd release in plasma (≤6.5%); biliary/fecal excretion
“Tissues with the highest concentrations of radioactivity included the small and large intestines, urinary bladder, and kidney.”
✓ VerifiedFDA multi-discipline review, p. 45Source ↗

Decnupaz

pivekimab sunirine · CD123
Immune & cytokine safety
ADA in monkeys reduced exposure; thymic lymphoid depletion and lymphopenia; ADCC present in vitro
“In animals that were ADA positive, there was a noticeable decrease in systemic exposure to both PVEK and TAb on Day 85 vs Day 1.”
✓ VerifiedFDA multi-discipline review, p. 47Source ↗
Biodistribution & persistence
[3H]PVEK in rat: highest in marrow, liver, kidney, lung, heart, spleen; tissue:plasma <1; mainly fecal/biliary excretion
“The highest concentrations of radioactivity were observed in tissues with high blood volume: bone marrow, liver, kidneys, lungs, heart and spleen.”
✓ VerifiedFDA multi-discipline review, p. 49Source ↗

Elahere

mirvetuximab soravtansine · FRα
Immune & cytokine safety
No ADA in any monkey up to 8 mg/kg; bone marrow and lymphoid depletion; no stand-alone immunotox
“All monkeys administered mirvetuximab soravtansine at doses up to 8 mg/kg/dose tested negative for the presence of anti-drug antibodies (ADAs).”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗
Biodistribution & persistence
Rat radiolabel: liver, bone marrow, lung, kidney, spleen highest; slow ocular clearance; testis penetration; brain <3%; fecal elimination
“The eye:plasma ratio increased through the duration of the study, suggesting that drug clearance from the eyes was slower than from plasma.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗

Emrelis

telisotuzumab vedotin · c-Met
Immune & cytokine safety
No substantial cytokine release from human PBMC; no ADA in 13-week monkey study; low C1q, no complement activation
“In an analysis of cytokine induction in PBMC cultures, telisotuzumab vedotin did not trigger any substantial release of pro-inflammatory cytokines IL-1b, IL-2, IL-6, TNF-α or IFN-γ from human PBMC after 48-hour treatment.”
✓ VerifiedFDA multi-discipline review, p. 40Source ↗
Biodistribution & persistence
MMAE widely distributed in rat (bile, GI tract, bladder), mainly fecal elimination; ADC target-mediated disposition in monkey
“Radiolabeled MMAE was widely distributed following single IV administration to rats, with highest concentrations in the bile, gastrointestinal (GI) tract, and urinary bladder.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗

Enhertu

fam-trastuzumab deruxtecan · HER2
Immune & cytokine safety
No treatment-emergent ADA in rat or monkey studies; ADCC activity retained in vitro
“In the monkey studies, only pre-dose samples in a few animals in two of the four studies showed detectable ADA (one male in study SBL315-031, 3 animals in Study SBL315-526).”
✓ VerifiedEMA assessment report, p. 55Source ↗
Biodistribution & persistence
Monkey 14C-ADC: highest in large intestinal contents, blood, lung, adrenal, liver; minimal CNS; mainly fecal excretion
“After a single administration of 6.4 mg/kg 14C-DS-8201a IV, the highest radioactivity was observed in the large intestinal contents, followed by the blood, lung, adrenal gland, and liver (all tissue-to-blood ratios were less than 1).”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗

Kadcyla

ado-trastuzumab emtansine · HER2
Immune & cytokine safety
No ADA detected after single dose in monkey safety pharmacology study; ADA assessed across monkey studies
“Blood samples for anti-drug antibody analysis were taken pre-dose and on Day 22. No anti-drug antibodies were detected in the post dose samples.”
✓ VerifiedEMA assessment report, p. 20Source ↗
Biodistribution & persistence
Confined largely to plasma; distribution parallels blood flow (lung, kidney, liver); no tissue persistence; predominantly fecal excretion
“Neither T-DM1 nor free DM1 were associated with tissue persistence or accumulation.”
✓ VerifiedEMA assessment report, p. 23Source ↗

Mylotarg

gemtuzumab ozogamicin · CD33
Immune & cytokine safety
ADA in rats (reduced exposure) and some monkeys; marked eosinophilia and hypersensitivity reactions in monkeys
“Marked eosinophilia occurred at all dose levels and was associated with hypersensitivity reactions in few monkeys dosed with the old cell line.”
✓ VerifiedFDA pharmacology/toxicology review, p. 19Source ↗
Biodistribution & persistence
Rat [3H]-ADC tissue distribution limited (tissue/plasma <=0.54; liver, kidney, spleen highest); little in vivo payload release
“In rats, distribution of [3H]gemtuzumab ozogamicin radioequivalents into red blood cells and tissues was limited, with tissue-to-plasma AUC ratios ≤ 0.54 for all tissues evaluated.”
✓ VerifiedEMA assessment report, p. 29Source ↗

Padcev

enfortumab vedotin · Nectin-4
Immune & cytokine safety
ADA in rats and monkeys reduced exposure on repeat dosing; no ADCC/CDC, ADCP activity in vitro
“Decreases in systemic exposure levels were reported in rats and monkeys following repeat dosing (Day 85 or 22, respectively), due to the presence of anti-drug antibodies (ADAs).”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗
Biodistribution & persistence
Rat [3H]MMAE QWBA: wide distribution, bile/bladder highest; prolonged uveal retention (melanin binding); fecal excretion
“Elimination of radioactivity from most tissues was observed at 96 hours post dose, except for the eye uveal tract (t½ = 672 hours post dose), indicating that [ 3H]MMAE likely bound melanin.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗

Polivy

polatuzumab vedotin · CD79b
Immune & cytokine safety
Surrogate ADC depleted B cells (expected pharmacology); ADA in monkeys without exposure impact
“Anti-drug-antibodies to polatuzumab vedotin or the surrogate ADC did not appear to impact exposure at any dose level and the toxicokinetic (TK) profiles were similar between ADA-positive and ADA-negative animals.”
✓ VerifiedFDA pharmacology/toxicology review, p. 12Source ↗
Biodistribution & persistence
Rat: non-specific distribution to highly perfused tissues peaking ~2 h; MMAE eliminated >95% in feces
“In a combined distribution and elimination study, MMAE and MMAE-related catabolites of polatuzumab vedotin were primarily eliminated through the hepatobiliary pathway in rats: >95% in feces, ~5% in urine.”
✓ VerifiedFDA pharmacology/toxicology review, p. 11Source ↗

Tivdak

tisotumab vedotin · Tissue factor
Immune & cytokine safety
ADA in most monkeys after repeat dosing, reduced exposure in some; immunotoxic potential minimal
“Most monkeys developed ADAs following repeated doses of tisotumab vedotin.”
✓ VerifiedEMA assessment report, p. 51Source ↗
Biodistribution & persistence
Monkey 89Zr-PET: highest uptake liver and bone marrow (~20% each); MMAE fecal elimination
“In cynomolgus monkeys, liver and bone marrow received the highest percent (approx. 20% each) of the injected dose of 89Zr-tisotumab and long persistence were noted.”
✓ VerifiedEMA assessment report, p. 39Source ↗

Trodelvy

sacituzumab govitecan · Trop-2
Immune & cytokine safety
ADA in all monkeys at all doses in 13-week study, reducing low-dose exposure; reduced thymic/lymphoid cellularity
“Anti-drug antibodies were detected in all animals at all doses tested in the chronic toxicity study.”
✓ VerifiedFDA multi-discipline review, p. 176Source ↗
Biodistribution & persistence
Mouse xenograft: radiolabeled ADC to tumour plus liver, spleen, kidney, lung; SN-38 released in serum (t1/2 ~1-2 days); free SN-38 ~2.3% of total
“In addition to tumour, both hRS7 and sacituzumab govitecan distributed to normal tissues, primarily to liver, spleen, kidney and lungs among the normal tissues analysed.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Zynlonta

loncastuximab tesirine · CD19
Immune & cytokine safety
Pro-inflammatory responses (WBC, fibrinogen, multi-organ inflammation) typical of PBD ADCs; ADA in few monkeys
“Treatment of monkeys with loncastuximab tesirine resulted in pro‐inflammatory responses as indicated by increases in the white blood cells (WBCs) and/or differentials, increased fibrinogen, and histopathology observations (multi‐organ inflammation, particularly the lung, kidney, or injection site).”
✓ VerifiedFDA multi-discipline review, p. 39Source ↗
Biodistribution & persistence
ADC confined to plasma volume, t1/2 8-17 days, stable; [3H]-SG3199 rapid wide distribution, no brain/melanin uptake, biliary excretion
“There was no apparent distribution of SG3199 to melanin‐ containing tissues or the brain or spinal cord.”
✓ VerifiedFDA multi-discipline review, p. 38Source ↗