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What safety margins were accepted 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
10 of 14 reviews state the margin; median 2.5× human exposure at the NOAEL, 2 below 1×.
Oncology: median 2.5× (0.1×–7×); 2 below 1×10/14
Not stated in public reviews4/14
0.1×0.3×1×3×10×30×100×
Oncology

Multiple of human exposure at the recommended dose, at the pivotal NOAEL (HNSTD for oncology), as stated by the regulator. Left of 1× = below human exposure; reviews that say "below human exposure" without a number sit at <1×.

Precedent by precedent

14 approved ADCs, with the reviewers' own words.

Elahere

mirvetuximab soravtansine · FRα
Safety margin at NOAEL
Monkey NOAEL 4 mg/kg: AUC margin 0.09 (AUC0-24 vs AUCtau) to 0.57 (AUC0-∞)
“When monkey AUC0-24 was compared to human AUCtau (area under the concentration vs. time curve over the dosing interval 21 days) exposure margin was 0.09; however, when monkey AUC0-∞ was used for comparison the exposure multiple was 0.57.”
✓ VerifiedEMA assessment report, p. 56Source ↗
NOAEL / key findings
10-week monkey NOAEL 4 mg/kg q3w (Cmax margin ~1); single-dose HNSTD 10 mg/kg, NOAEL 3 mg/kg; cornea, skin, bone marrow
“In a 10-week toxicity study in monkeys a mid-dose of 4 mg/kg/dose Q3W of MIRV was selected to characterize potential toxicity at an exposure metric which was predicted to be similar to that of the IV dose (6 mg/kg, AIBW) utilized for the registrational studies. This dose was considered as NOAEL.”
✓ VerifiedEMA assessment report, p. 56Source ↗

Datroway

datopotamab deruxtecan · Trop-2
Safety margin at NOAEL
Monkey NOAEL 10 mg/kg (lung, cornea, skin, liver, thymus): margin of exposure 0.25 (below human exposure)
“The NOAEL for pulmonary, corneal, dermal, hepatic and lymphoid (thymic) toxicity was concluded to be 10 mg/kg corresponding to a margin of exposure of 0.25.”
✓ VerifiedEMA assessment report, p. 52Source ↗
NOAEL / key findings
Monkey NOAEL 10 mg/kg for lung, cornea, skin, liver, thymus (intestinal toxicity at ≥10); rat NOAEL 20-60 mg/kg; ADA limits margins
“The NOAELs for pulmonary, corneal, dermal, hepatic, and lymphoid (thymic) toxicity was concluded to be 10 mg/kg.”
✓ VerifiedFDA multi-discipline review, p. 66Source ↗

Besponsa

inotuzumab ozogamicin · CD22
Safety margin at NOAEL
No NOAEL for rat male reproductive effects, seen at ~0.3x human AUC
“The NOAEL was not identified for the effects on male reproductive organs, which were observed at approximately 0.3 times the human clinical exposure based on AUC (SmPC section 5.3).”
✓ VerifiedEMA assessment report, p. 42Source ↗
NOAEL / key findings
No NOAEL in rat or monkey chronic studies; liver (sinusoidal injury), hematolymphoid, reproductive organs; monkey glomerulonephritis death at 5 ug/kg
“Taken together, the primary inotuzumab ozogamicin target organs identified by the chronic toxicity studies were the liver, hematolymphopoietic tissues, and the male and female reproductive organs.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗

Kadcyla

ado-trastuzumab emtansine · HER2
Safety margin at NOAEL
Monkey HNSTD 10 mg/kg (2040 µg DM1/m2) approximately equivalent to the clinical dose
“Administration of trastuzumab emtansine was well tolerated in rats and monkeys at doses up to 20 and 10 mg/kg, respectively, corresponding to 2040 µg DM1/m2 in both species, which is approximately equivalent to the clinical dose of trastuzumab emtansine in patients.”
✓ VerifiedEMA assessment report, p. 36Source ↗
NOAEL / key findings
Monkey HNSTD 10 mg/kg q3w; liver enzymes, thrombocytopenia, lymphoid atrophy, axonal degeneration (sciatic nerve, spinal cord) at >=10 mg/kg
“Based on overall tolerability and reversibility of findings, the Applicant considered 10 mg/kg of trastuzumab emtansine given as four injections to Cynomolgus monkeys every 3 weeks to be the highest non-severely toxic dose.”
✓ VerifiedFDA pharmacology/toxicology review, p. 153Source ↗

Tivdak

tisotumab vedotin · Tissue factor
Safety margin at NOAEL
Monkey HNSTD 3 mg/kg ~1.35-2.56x human exposure (Cmax and AUC)
“The applicant also provided exposure (Cmax and AUC) ratios between monkey and human at the highest non-severely toxic dose of 3 mg/kg, which was approximately 1.35- to 2.56-fold that in humans.”
✓ VerifiedEMA assessment report, p. 50Source ↗
NOAEL / key findings
Monkey NOAEL 1 mg/kg (females; <1 mg/kg males), HNSTD 3 mg/kg; skin, bone marrow, eye, testes; skin deaths at 5 mg/kg
“The NOAEL for males was <1 mg/kg. The applicant also provided exposure (Cmax and AUC) ratios between monkey and human at the highest non-severely toxic dose of 3 mg/kg, which was approximately 1.35- to 2.56-fold that in humans.”
✓ VerifiedEMA assessment report, p. 50Source ↗

Adcetris

brentuximab vedotin · CD30
Safety margin at NOAEL
Monkey NOAEL serum exposure ~2 to 3x human exposure at the clinical dose
“The serum exposure to SGN-35 in monkeys at the NOAEL was approximately 2 to 3 times that in humans.”
✓ VerifiedEMA assessment report, p. 32Source ↗
NOAEL / key findings
Monkey NOAEL 1 mg/kg, HNSTD 3 mg/kg, 6 mg/kg lethal; rat HNSTD 5 mg/kg; bone marrow/neutropenia, lymphoid, rat liver and testis
“At 3 mg/kg (HNSTD), a similar, but less severe cyclic decrease in neutrophil counts was observed, while at 1 mg/kg (NOAEL) no biologically relevant effects on neutrophil counts was observed.”
✓ VerifiedEMA assessment report, p. 37Source ↗

Padcev

enfortumab vedotin · Nectin-4
Safety margin at NOAEL
Monkey ~3-fold and rat (MTD) ~2-fold human systemic exposure at recommended dose
“The systematic exposure to AGS-22M6E in cynomolgus monkeys was ~3-fold the human systemic exposure at the recommended clinical dose. In rats, at the maximum tolerated dose (MTD), the systematic exposure was also ~2-fold the human systemic exposure at the recommended clinical dose.”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗
NOAEL / key findings
Monkey HNSTD/MTD 3 mg/kg, rat MTD 5 mg/kg; skin, injection site, bone marrow, liver, eye, male reproductive organs
“In the 4-week monkey study (# 20005664), AGS-22M6E systemic exposure at 3 mg/kg (MTD/HNSTD) was 2450 µg.hr/mL (Day 1) and 903 µg.hr/mL (Day 22).”
✓ VerifiedFDA multi-discipline review, p. 56Source ↗

Zynlonta

loncastuximab tesirine · CD19
Safety margin at NOAEL
Monkey 0.3 mg/kg ~3x human AUC at MRHD 0.15 mg/kg
“The dose of 0.3 mg/kg in animals results in an exposure (AUC) that is approximately 3 times the exposure at the maximum recommended human recommended dose [MRHD] of 0.15 mg/kg.”
✓ VerifiedFDA multi-discipline review, p. 39Source ↗
NOAEL / key findings
No NOAEL stated; 13-week monkey kidney and testis findings at all doses (≥0.075 mg/kg); skin hyperpigmentation dose-limiting; bone marrow, lung
“Also, adverse findings in male reproductive organs were present at 0.6 mg/kg only in the 4‐week study and at all doses (≥ 0.075 mg/kg) in the 13‐week study.”
✓ VerifiedFDA multi-discipline review, p. 51Source ↗

Trodelvy

sacituzumab govitecan · Trop-2
Safety margin at NOAEL
Monkey NOAEL/HNSTD 50 mg/kg: 6.4x (total antibody), 4.6x (total SN-38), 3.1x (free SN-38) human exposure at 10 mg/kg
“A comparison of the exposure in cynomolgus at the NOAEL/HNSTD (50 mg/kg) and in humans at the proposed clinical dose (10 mg/kg) was made. The exposure margin was 6.4x for total antibody, 4.6x for total SN-38 and 3.1x for free SN-38.”
✓ VerifiedEMA assessment report, p. 31Source ↗
NOAEL / key findings
Acute study HNSTD 60 mg/kg (no NOAEL); 13-week NOAEL/HNSTD 50 mg/kg; bone marrow, lymphoid, GI, liver, skin, female reproductive organs
“In the absence of a NOAEL, the HNSTD in this study was 60 mg/kg/dose.”
✓ VerifiedEMA assessment report, p. 30Source ↗

Enhertu

fam-trastuzumab deruxtecan · HER2
Safety margin at NOAEL
Monkey 30 mg/kg (3-month study) ≥7x human AUC at 5.4 mg/kg
“In a three-month repeat-dose toxicity study in monkeys, intravenous administration of DS-8201a decreased numbers of round spermatids in the testes at seminiferous tubule stages V to VI at doses ≥ 30 mg/kg (≥ 7 times the exposure at the human recommended dose of 5.4 mg/kg based on AUC).”
✓ VerifiedFDA multi-discipline review, p. 43Source ↗
NOAEL / key findings
HNSTD 30 mg/kg monkey, 197 mg/kg rat; bone marrow, intestine, skin, lung, testis, kidney; lung toxicity at 78.8 mg/kg
“The highest non-severely toxic dose of trastuzumab deruxtecan was established at 197 mg/kg in rats (non-binding species), and 30 mg/kg in cynomolgus monkey”
✓ VerifiedEMA assessment report, p. 49Source ↗

Decnupaz

pivekimab sunirine · CD123
Safety margin at NOAEL
No NOAEL in 13-week monkey study: thymic atrophy at the lowest dose (0.01 mg/kg)
“Adverse toxicity was observed at all doses since even the lowest tested dose of 0.01 Ab mg/kg produced thymic atrophy in males.”
✓ VerifiedFDA multi-discipline review, p. 61Source ↗
NOAEL / key findings
FDA: no NOAEL in 13-week (thymic atrophy ≥0.01 mg/kg); single-dose max nonlethal 0.4 mg/kg; marrow, GI, skin, thymus
“Adverse toxicity was observed at all doses since even the lowest tested dose of 0.01 Ab mg/kg produced thymic atrophy in males.”
✓ VerifiedFDA multi-discipline review, p. 61Source ↗

Emrelis

telisotuzumab vedotin · c-Met
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
13-week cyno: no adverse findings to 3 mg/kg; 4-week: neutropenia/marrow at ≥6 mg/kg, ovary/uterus ≥3 mg/kg, eye, thymus
“Myelosuppression occurred at the middle and high doses, which correlated histologically with decreased bone marrow cellularity.”
✓ VerifiedFDA multi-discipline review, p. 34Source ↗

Mylotarg

gemtuzumab ozogamicin · CD33
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
6-week NOAEL 2.4 mg/m2/wk monkey, 0.6 rat; 12-week monkey no NOAEL; liver, kidney, marrow, lymphoid, reproductive organs
“The NOAEL was defined at 2.4 mg/m2 /week based on target organ toxicity in the kidney, liver, and lympho-hematopoietic organs at ≥7.2 mg/m2 /week.”
✓ VerifiedFDA pharmacology/toxicology review, p. 18Source ↗

Polivy

polatuzumab vedotin · CD79b
Safety margin at NOAEL
Not stated in public reviews
NOAEL / key findings
Rat STD10 10 mg/kg; monkey surrogate HNSTD 3 mg/kg; bone marrow, lymphoid, liver, male reproductive organs (testes irreversible)
“The main target organs are bone marrow, lymphoid organs, reproductive organs and liver with less severe effects on eye, skin and pancreas.”
✓ VerifiedEMA assessment report, p. 55Source ↗