Subsection 2: Investigation, authorisation, refusal, renewal

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Article R5121-69-4

French Public Health CodeIn force

Updated 2 Nov 2023

I.-The early access authorisation may be renewed.

Renewal is the subject of an application by the holder of this authorisation addressed to the Haute Autorité de santé, the ministers responsible for health and social security and, for applications relating to a medicinal product mentioned in 1° of II of Article L. 5121-12, to the Agence nationale de sécurité du médicament et des produits de santé, with the exception of renewals granted under the conditions mentioned in III of Article R. 5121-72.

II.- The application for renewal is addressed in accordance with the procedures defined in I of Article R 5121-68 no later than three months before the expiry date of the authorisation.Applications for renewal must be submitted in accordance with the procedures defined in I of article R 5121-68 no later than three months before the expiry date of the authorisation. This application must be accompanied by the updated information mentioned in article R. 5121-68 as well as any information obtained during the previous authorisation period on the medicinal product in question, in particular the periodic summary report, and the consequences of its use.

III. -The examination of the application and the conditions under which the decision to grant early access authorisation is taken, as defined in III and IV of article R. 5121-68 and in articles R. 5121-69 and R. 5121-69-1, are applicable to decisions concerning the renewal of this access.

The previous authorisation remains in force until the Haute Autorité de santé has taken a decision on the application for renewal and at the latest until the expiry date of the period provided for in 1° of I of Article R. 5121-69-2, possibly extended by the periods provided for in IV of Article R. 5121-68, in I of Article R. 5121-69 and in Article R. 5121-69-1.

IV. - The Haute Autorité de santé refuses to renew the authorisation.The Haute Autorité de Santé will refuse renewal of the early access authorisation if the conditions set out in article L. 5121-12 are not met, if the obligations set out in this article are not complied with or for any other public health reason, in accordance with the same procedures as those set out in article R. 5121-69.

V.-In the event of a decision by the Haute Autorité de santé refusing to renew the early access authorisation, this authorisation is consequently deemed to have been withdrawn.

Mariela Petrova

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Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

Avocate au Barreau de Paris

Toque #C2396

15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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