Replimune · RP1 · Oct 2025

What did Replimune resubmit in October 2025, and what did the FDA make of it?

An early look at 40 patients in the Phase 3 trial and new analyses of the single-arm trial. The FDA set an action date of April 10, 2026, the date of the second letter.

EphemerisX Research · Published · 3 source documents · 1 min read

Short answer

The resubmission added an early, unplanned analysis of the Phase 3 trial (22 patients on RP1 with nivolumab, 18 on the control arm, 10% of planned enrollment) and exploratory analyses of the single-arm trial. The FDA set an action date of April 10, 2026, and issued its second letter that day.

What the evidence shows

In October 2025 the company said Additional information, data and analyses were included in the resubmission 8-K · Oct 20, 2025, and that The PDUFA date set by the FDA is April 10, 2026 based on a Class II resubmission timeline 8-K · Oct 20, 2025.

The second letter lists them: ORR data from an early unplanned analysis from your ongoing, randomized, Phase 3 trial, RP1-104 FDA · Apr 10, 2026 · p. 2, representing 10% of the planned enrollment of 400 patients FDA · Apr 10, 2026 · p. 2, and exploratory analyses of progression-free survival, and of response in patients who had both injected and non-injected tumors FDA · Apr 10, 2026 · p. 2.

The letter places it after the Type A meeting: Instead, you submitted data from an early unplanned analysis from RP1-104 FDA · Apr 10, 2026 · p. 4. On the Phase 3 data it lists Limited number of patients treated to date (10% of the planned study population) FDA · Apr 10, 2026 · p. 2, Response assessment performed only by investigator FDA · Apr 10, 2026 · p. 2 and Lack of duration of response data FDA · Apr 10, 2026 · p. 2, and concludes: This data is insufficient to support an efficacy claim FDA · Apr 10, 2026 · p. 4. The exploratory analyses do not alter our initial conclusion FDA · Apr 10, 2026 · p. 2.

Replimune's April 2026 8-K cites one of those analyses: median progression free survival on RP1 plus nivolumab was 30.6 months compared to 4.4 months on their prior PD-1 based regimen 8-K · Apr 13, 2026. The 8-K does not mention the early, unplanned Phase 3 analysis submitted with the resubmission. 8-K · searched

Follow the thread

This investigation connects to

The documents, by date

Replimune Form 8-K, filed October 20, 20258-K · Oct 20, 2025FDA Complete Response Letter, April 10, 2026FDA letter · Apr 10, 2026Replimune Form 8-K, filed April 13, 20268-K · Apr 13, 2026

The passages quoted

Replimune Form 8-K, filed October 20, 2025

The PDUFA date set by the FDA is April 10, 2026 based on a Class II resubmission timeline.
Open at the source →

Replimune Form 8-K, filed October 20, 2025

Additional information, data and analyses were included in the resubmission which will be part of the BLA review. The FDA indicated this resubmission is considered to be a complete response to the complete response letter received in July 2025.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 2

You also provided results from additional exploratory analyses of RPL-001-16, including analyses of patients who had a response to immediate prior anti-PD1 therapy and their subsequent response to the combination of vusolimogene oderparepvec and nivolumab, of progression-free survival, and of response in patients who had both injected and non-injected tumors.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 2

Therefore, the evidence as presented does not meet the evidentiary standards required for regulatory approval, and the results of the additional exploratory analyses of the RPL-001-16 data do not alter our initial conclusion that the RPL-001-16 trial is not an adequate and well-controlled clinical investigation that demonstrates substantial evidence of effectiveness.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 2

To support resubmission of the BLA on October 9, 2025, you provided ORR data from an early unplanned analysis from your ongoing, randomized, Phase 3 trial, RP1-104, including 22 patients in the investigational arm of vusolimogene oderparepvec with nivolumab and 18 patients in the control arm (physician’s choice of treatment), representing 10% of the planned enrollment of 400 patients.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 2

For RP1-104 • Limited number of patients treated to date (10% of the planned study population) • Response assessment performed only by investigator, • Lack of duration of response data, and • Difficulty in interpreting progression-free survival data due to lack of pre-specification for this analysis and without adequate type 1 error control.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 4

Instead, you submitted data from an early unplanned analysis from RP1-104, representing 10% of the planned enrollment, as well as additional exploratory analyses of the RPL-001-16 data, to support BLA resubmission. This data is insufficient to support an efficacy claim.
Open at the source →

FDA Complete Response Letter, April 10, 2026 · page 4

This data is insufficient to support an efficacy claim.
Open at the source →

Replimune Form 8-K, filed April 13, 2026

The 8-K does not mention the early, unplanned Phase 3 analysis submitted with the resubmission.

Searched the whole document for: RP1-104, unplanned, interim, 10%, early analysis. None found.

Open the document →

Replimune Form 8-K, filed April 13, 2026

The company also included data from IGNYTE showing median progression free survival on RP1 plus nivolumab was 30.6 months compared to 4.4 months on their prior PD-1 based regimen.
Open at the source →

Prepared from public FDA letters and SEC filings: every quoted passage is matched to the original document, and every “not in” statement comes from a search of the whole document, before it is published. Questions, summaries and connecting sentences are EphemerisX’s wording. Not investment advice. How this research works → · Ask the FDA and SEC Ephemeris →