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Which risks did regulators probe for approved oligonucleotides?

From the FDA and EMA reviews of all 24 approved oligonucleotides. Each answer links to the regulator's own sentence.

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Short answer
What reviewers probed for each of the 24 approved oligonucleotides.

Precedent by precedent

24 approved oligonucleotides, with the reviewers' own words.

Amondys 45

casimersen · DMD exon 45 (PMO)
Immune & cytokine safety
Dose-related complement activation (Bb, C3a) in 12-week monkey; no immune function effects in juvenile rat
“Activation of complement, dose-related in magnitude, was observed in all SRP-4045 dose groups, as evidenced by increases in Bb and C3a.”
✓ VerifiedFDA pharmacology/toxicology review, p. 27Source ↗
Biodistribution & persistence
Extensive tissue distribution; highest kidney, lowest brain; urinary elimination complete by 336 h; low protein binding
“Protein binding was low (<37%) in animal and human plasma, and there was extensive tissue distribution, with highest and lowest levels of radioactivity in kidney and brain, respectively”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Amvuttra

vutrisiran · TTR (siRNA)
Immune & cytokine safety
No ADA in rats; non-dose-related ADA in 8/32 monkeys without impact; no cytokine stimulation in vitro or in monkeys
“Vutrisiran did not stimulate various cytokines in human whole blood samples in vitro and in a 13 weeks DRF toxicity study in monkeys in vivo.”
✓ VerifiedEMA assessment report, p. 28Source ↗
Biodistribution & persistence
Rat QWBA: highest in liver, lymph nodes, kidneys; detectable in all tissues at 672 h; not in fetal tissue
“Based on the QWBA data, radioactivity in tissues generally peaked by 48 hours postdose, and was highest in liver, lymph nodes, kidneys, and thoracic ducts.”
✓ VerifiedFDA pharmacology/toxicology review, p. 29Source ↗

Dawnzera

donidalorsen · Prekallikrein / KLKB1 (ASO)
Immune & cytokine safety
No cytokine/chemokine or C3 effects; minimal transient complement Bb increase at 30 mg/kg/week; ADAs 12.5-62.5% in monkey without impact
“A potential test article-related minimal increase in mean complement Bb levels was observed at 4 hours post-dose on Day 1 in animals at 30 mg/kg/week.”
✓ VerifiedEMA assessment report, p. 30Source ↗
Biodistribution & persistence
Highest in liver and kidney (GalNAc-targeted); liver exposure >1000-fold plasma; little in brain
“the highest concentrations of radioactivity were observed in the liver and kidney, at their tmax observed at 24- and 168-h post dose in the liver and kidney, respectively.”
✓ VerifiedEMA assessment report, p. 27Source ↗

Exondys 51

eteplirsen · DMD exon 51 (PMO)
Immune & cytokine safety
No effects on TDAR or immunophenotyping in juvenile rat; lymphoid necrosis in spleen/thymus at high dose in mouse
“No drug-related effects were observed on TDAR, immunophenotyping, physical development, neurobehavioral development, or on the male reproductive system.”
✓ VerifiedFDA pharmacology/toxicology review, p. 18Source ↗
Biodistribution & persistence
Rapid, widespread distribution; highest in kidney, low in brain; ~60% urinary excretion; only kidney retained at 56 days
“Widespread tissue distribution was detected by QWBA, with highest peak levels in kidney (165000 ng-eq/g). At 56 days postdose, radioactivity was detected only in kidney and urine.”
✓ VerifiedFDA pharmacology/toxicology review, p. 13Source ↗

Givlaari

givosiran · ALAS1 (siRNA)
Immune & cytokine safety
Low ADA incidence: rat negative, one monkey ADA-positive; no dedicated antigenicity studies
“All samples in the rat were negative. In the monkey study one sample was positive at 30 mg/kg/week (on day 169) and 3 samples were positive at 100 mg/kg/week, all from one animal (on days 85, 169 and 253).”
✓ VerifiedEMA assessment report, p. 45Source ↗
Biodistribution & persistence
Rat QWBA: liver, kidney cortex, lymph nodes highest; long liver/kidney half-lives; persists in liver, kidney, injection site at 28 days
“Quantitative whole-body autoradiography confirmed that givosiran is distributed to a limited number of tissues, with high exposures observed in the liver, kidneys, kidney cortex, and lymph nodes.”
✓ VerifiedFDA multi-discipline review, p. 27Source ↗

Izervay

avacincaptad pegol · C5 (aptamer)
Immune & cytokine safety
Main pharmacology-related risk is increased susceptibility to infections (C5 inhibition); no complement activation by the aptamer in monkeys; panuveitis with Lucentis combination
“Therefore, it seems that the main adverse reaction due to an exaggerated pharmacological effect of complement inhibition is an increased susceptibility to infections.”
✓ VerifiedFDA pharmacology/toxicology review, p. 36Source ↗
Biodistribution & persistence
Ocular tissue distribution in rabbit after single IVT 3 mg/eye; low systemic exposure (rabbit 51 ng/mL, dog 489 ng/mL); no accumulation in rabbit
“An ocular tissue distribution study was conducted in male Dutch-Belted rabbits following a single IVT injection of avacincaptad pegol (3 mg/eye) to both eyes”
✓ VerifiedFDA pharmacology/toxicology review, p. 37Source ↗

Kynamro

mipomersen · APOB (ASO)
Immune & cytokine safety
Class proinflammatory effects (MCP-1, IL-1b, CRP); alternative complement activation, C3 depletion in monkeys; no clear ADA
“Complement activation was apparent in monkeys at SC doses of > 20 mg/kg (~7x clinical exposure) and at intravenous (IV) doses as low as 12 mg/kg, as evidenced by transient rises in the level of the complement factor B split product, Bb, and the depletion of complement factor C3 with repeated dosing.”
✓ VerifiedFDA pharmacology/toxicology review, p. 21Source ↗
Biodistribution & persistence
Highest in kidney and liver, also spleen, lymph nodes, bone marrow; little in muscle, eye, brain; steady state 3-6 months
“The organs showing the highest tissue levels in all species are kidney, liver, spleen, lymph nodes and bone marrow, with the kidney and liver showing the highest concentrations. Little to no drug distributes to skeletal muscle, eye or the brain.”
✓ VerifiedFDA pharmacology/toxicology review, p. 20Source ↗

Leqvio

inclisiran · PCSK9 (siRNA)
Immune & cytokine safety
Delayed/suppressed TDAR (KLH IgM/IgG) in 40-week monkey study, reversible; sporadic low-titre ADA without PD impact
“In a 40-week toxicity study in NHPs, delayed or suppressed IgM (data not shown) and IgG (see Figure 1, below) responses were observed across the dose range at ≥ 2 times the clinical MRHD (BSA) (≥ 30 mg/kg Q4W) in response to keyhole limpet hemocyanin (KLH) sheep antigen”
✓ VerifiedFDA pharmacology/toxicology review, p. 5Source ↗
Biodistribution & persistence
QWBA: highest in injection site, liver, kidney cortex; minimal brain/CNS; slow tissue elimination (t1/2 >100 h)
“In rats, inclisiran-associated radioactivity widely distributed to most tissues with the highest concentrations (based on Cmax) observed at the subcutaneous dose site, and in the liver (target organ), and kidney cortex (site of elimination).”
✓ VerifiedFDA pharmacology/toxicology review, p. 26Source ↗

Macugen

pegaptanib · VEGF-165 (aptamer)
Immune & cytokine safety
No local/systemic immune response or antibody induction; antibody assay of unclear accuracy
“Overall, there were no indications that pegaptanib induced a local or systemic immune response and there were only minor effects on immune cells and organs at high exposures.”
✓ VerifiedEMA assessment report, p. 12Source ↗
Biodistribution & persistence
Retained in vitreous/retina; slow diffusion to systemic; kidney highest systemic; renal excretion
“After IVT administration, radioactivity was mainly located in the vitreous fluid, retina and aqueous humour at 24 hours post-dose.”
✓ VerifiedEMA assessment report, p. 6Source ↗

Onpattro

patisiran · TTR (siRNA)
Immune & cytokine safety
Transient complement activation (C3a, Bb) in monkeys, siRNA-independent; ADA to PEG lipid in rats reduced exposure
“Data from the 6-week study indicate that administration of patisiran-LNP or AF-011-1955 resulted in transient complement activation after 15 minutes, 6h and 24 h after dosing.”
✓ VerifiedEMA assessment report, p. 43Source ↗
Biodistribution & persistence
>90% of LNP to liver in rat QWBA; also spleen, kidney, lymph nodes, adrenals; minimal CNS
“Based on male adult rat autoradiography (QWBA) studies with 0.3mg/kg single dose IV patisiran-LNP with radiolabelled 14C-DLin-MC3-DMA, most of the radioactivity (>90%) is rapidly distributed to the liver”
✓ VerifiedEMA assessment report, p. 37Source ↗

Oxlumo

lumasiran · HAO1 (siRNA)
Immune & cytokine safety
Low-titre ADA in 3/36 monkeys, no impact on exposure or tox; no ADA in rats; not immunostimulatory
“A low incidence, 3 out of 36 treated monkeys in the 36- week repeat-dose toxicity study (GO1-GLP15-036) were confirmed to have a low titre of anti-lumasiran antibodies.”
✓ VerifiedEMA assessment report, p. 42Source ↗
Biodistribution & persistence
Rat: liver, kidney cortex/medulla highest; not detected in brain/spinal cord; long liver half-life (585 h) in monkey
“Relatively high tissue concentrations (in descending order) were observed in the liver, kidney cortex, kidney medulla, cecum, salivary gland, bone marrow, thyroid and pancreas.”
✓ VerifiedFDA integrated review, p. 56Source ↗

Qalsody

tofersen · SOD1 (ASO)
Immune & cytokine safety
CSF inflammation at 35 mg in monkey; ADA not assessed in animal studies (58.4% of patients ADA-positive)
“The development of anti-tofersen antibodies was not investigated in the chronic toxicity studies in rat, mice and monkeys.”
✓ VerifiedEMA assessment report, p. 32Source ↗
Biodistribution & persistence
Rapid CSF-to-CNS tissue distribution with transfer to systemic circulation; long CSF/CNS half-life (20-45 days, monkey)
“The rapid distribution phase is due to the rapid and broad distribution from the CSF to the CNS tissues with additional clearance due to transfer to the systemic circulation.”
✓ VerifiedEMA assessment report, p. 29Source ↗

Qfitlia

fitusiran · Antithrombin / SERPINC1 (siRNA)
Immune & cytokine safety
No ADA in monkeys (0.1-1 mg/kg/week); injection-site hypersensitivity-type skin reactions in rats and monkeys at all doses
“Fitusiran increased the incidence of hypersensitivity reactions (skin redness/dryness/scab/discharge at the injection site) in rats and monkeys at all doses tested.”
✓ VerifiedFDA integrated review, p. 89Source ↗
Biodistribution & persistence
Rapid hepatic uptake and slow liver clearance (liver t1/2 ~55-60 h); liver >> kidney, spleen; negligible exposure in brain, heart
“Fitusiran distributed mainly to liver (the primary target organ of pharmacology), followed by kidney and spleen.”
✓ VerifiedFDA integrated review, p. 151Source ↗

Redemplo

plozasiran · APOC3 (siRNA)
Immune & cytokine safety
Proinflammatory cytokines induced in human whole blood in vitro at high concentrations; none in rat/monkey studies
“No induction of proinflammatory cytokines or inflammation were noted in the completed rat and monkey toxicity studies at doses higher than the plasma concentrations expected at MRHD”
✓ VerifiedFDA integrated review, p. 261Source ↗
Biodistribution & persistence
High liver concentration (>100-fold other sites), liver half-life ~4-5 days in rats
“revealed high liver concentration (>100-fold) compared to other sites and a prolonged liver elimination half-life (~4 to 5 days)”
✓ VerifiedFDA integrated review, p. 103Source ↗

Rivfloza

nedosiran · LDHA (siRNA)
Immune & cytokine safety
No cytokine or complement activation in 39-week monkey study; nonclinical ADA not assessed
“No test article-related effect on cytokine activation was evident at any time point evaluated.”
✓ VerifiedFDA integrated review, p. 94Source ↗
Biodistribution & persistence
Mainly liver, less kidney; other tissues <2% of liver; long liver half-life (12-23 days)
“Nedosiran is distributed primarily to the liver, and to a lesser extent to the kidney.”
✓ VerifiedFDA integrated review, p. 90Source ↗

Rytelo

imetelstat · Telomerase (oligo)
Immune & cytokine safety
Alternative complement activation (Bb, C5a); no immunotoxicity; no ADA assessment in animals
“No immunogenicity (e.g., anti-drug antibody) assessment has been conducted.”
✓ VerifiedEMA assessment report, p. 38Source ↗
Biodistribution & persistence
Highest in liver and kidney, then bone marrow and spleen; urinary excretion
“The highest concentration of imetelstat was seen in the liver and kidney, followed by the bone marrow and spleen.”
✓ VerifiedFDA multi-discipline review, p. 42Source ↗

Spinraza

nusinersen · SMN2 (ASO)
Immune & cytokine safety
No complement activation or systemic inflammation in IT monkey studies; proinflammatory effects in mice
“In the 14- and 53-week juvenile monkey studies, no drug-related mortality or effects on body weight, ECG, CSF chemistry/cell counts, clinical pathology, or complement activation (as measured by concentrations of Bb split product) were observed”
✓ VerifiedFDA pharmacology/toxicology review, p. 7Source ↗
Biodistribution & persistence
Substantial CSF-to-systemic transfer; liver/kidney levels similar to spinal cord; CSF t1/2 ~102-111 days
“Concentrations in systemic tissues like liver and kidney following IT administration were similar to those seen in the spinal cord indicating that a substantial proportion of the administered dose was transferred from CSF to the systemic circulation.”
✓ VerifiedFDA pharmacology/toxicology review, p. 71Source ↗

Tegsedi

inotersen · TTR (ASO)
Immune & cytokine safety
Monkey perivascular inflammation with ADA, CRP, IL-6, TNFa, IgG/IgM rises; complement Bb activation; ADA in some monkeys
“In the same study, five other animals across the three lowest dose groups showed perivascular mixed cell infiltration in multiple organs, associated with increases in anti-drug antibody, CRP, IL-6, MIP-1β, TNFα, and serum IgG and IgM”
✓ VerifiedFDA pharmacology/toxicology review, p. 14Source ↗
Biodistribution & persistence
Rapid plasma-to-tissue distribution; high levels in kidney, liver, lymph nodes, injection site, bone marrow
“High concentrations of inotersen were detected in kidneys, liver, mesenteric lymph nodes, injection site and bone marrow.”
✓ VerifiedEMA assessment report, p. 22Source ↗

Tryngolza

olezarsen · APOC3 (ASO)
Immune & cytokine safety
Complement activation (Bb up, C3 down) in monkeys; MCP-1/CRP/IFN-gamma increases; ADAs in 25-62.5% of monkeys
“Dose-dependent increases in complement Bb were seen at all dosages.”
✓ VerifiedFDA integrated review, p. 104Source ↗
Biodistribution & persistence
Rapid distribution to liver and kidney; ASGPR-mediated liver uptake saturates at high doses
“Distribution to tissues in mouse and monkey was responsible for the initial rapid plasma clearance, with the highest concentrations present in liver and kidney.”
✓ VerifiedFDA integrated review, p. 217Source ↗

Viltepso

viltolarsen · DMD exon 53 (PMO)
Immune & cytokine safety
No cytokine or immunophenotype effects; transient ~2-fold C3 rise at high dose in mouse; no anti-drug antibodies
“There were no drug effects on C3 after dosing on Day 0; however, on Day 175, there was an approximate 2-fold elevation in serum C3 24 h after dosing in HDM.”
✓ VerifiedFDA pharmacology/toxicology review, p. 24Source ↗
Biodistribution & persistence
Radiolabel in monkey: highest in kidney cortex, low skeletal muscle levels; low protein binding
“With multiple doses (20 mg/kg/week for 8 weeks), highest levels of dose radioactivity were in kidney cortex (819 µg-Eq/g), with concentrations in skeletal muscle of 0.331- 0.479 µg-Eq/g.”
✓ VerifiedFDA pharmacology/toxicology review, p. 3Source ↗

Vyondys 53

golodirsen · DMD exon 53 (PMO)
Immune & cytokine safety
Transient complement activation (Bb, C3a) in 12-week monkey; no immune function effects in juvenile rat
“No drug-related findings were observed in the 12-week study, except for transient (Day 8) increases in complement B6 fragment and C3a at the mid and high doses and a dose-related decrease in FSH (Day 80).”
✓ VerifiedFDA pharmacology/toxicology review, p. 6Source ↗
Biodistribution & persistence
Rapid, extensive distribution except CNS; highest in kidney; blood t1/2 1.46 h; ~75% excreted intact in urine
“The drug was rapidly and extensively distributed to most tissues except CNS (brain and spinal cord). Highest levels of radioactivity were observed in kidney.”
✓ VerifiedFDA pharmacology/toxicology review, p. 111Source ↗

Wainua

eplontersen · TTR (ASO)
Immune & cytokine safety
Transient complement Bb increases; non-neutralising ADAs in chronic monkey study; minimal cytokine changes
“Thus, these ADAs represent binding antibodies without neutralising capacity.”
✓ VerifiedEMA assessment report, p. 32Source ↗
Biodistribution & persistence
Distributes mainly to liver and kidney; undetectable in brain and spinal cord (rat)
“In SD rats administered [3H]ASO-eplontersen, radioactivity levels peaked in plasma at 0.5 h postdose, then distributed into tissues, primarily liver and kidney, with the highest levels observed in the liver at 8 h and kidney at 2 days; radioactivity was undetectable in brain and spinal cord.”
✓ VerifiedFDA integrated review, p. 128Source ↗

Waylivra

volanesorsen · APOC3 (ASO)
Immune & cytokine safety
Complement activation in monkeys (class effect, species-specific); cytokine/chemokine increases (MCP-1, MIP-1b); anti-volanesorsen antibodies in 50-72% of monkeys
“Complement activation is seen in monkeys, a known effect of antisense oligonucleotides and considered species specific.”
✓ VerifiedEMA assessment report, p. 42Source ↗
Biodistribution & persistence
Liver and kidney accumulation, tissue concentrations hundreds-thousands-fold above plasma; tissue t1/2 12.5-32 days
“For all evaluated dose levels, volanesorsen concentrations 48 hours after the last dose (Day 93) were several hundred-to several thousand-fold higher in kidney cortex and liver than in plasma.”
✓ VerifiedEMA assessment report, p. 28Source ↗

Zanvastro

zilganersen · GFAP (ASO)
Immune & cytokine safety
Low-severity proinflammatory findings (liver mononuclear infiltrates, vacuolated macrophages) in 26-week SC mouse study
“revealed findings consistent with ASO uptake, accumulation, and a proinflammatory response, including basophilic granules in Kupffer cells, mononuclear cell infiltration in the liver, and vacuolated/granular macrophages in multiple tissues”
✓ VerifiedFDA integrated review, p. 75Source ↗
Biodistribution & persistence
SC dosing: dose-dependent maternal/paternal liver accumulation; very low to undetectable in placenta and fetal liver
“Zilganersen concentrations increased in a dose-dependent manner in maternal and paternal liver, but were very low to undetectable in placenta and fetal liver.”
✓ VerifiedFDA integrated review, p. 75Source ↗