Regulatory Compliance

FDA Diversity Action Plans: From Mandate to Reality in 2026

Joseph Farrell
3 min

As we close out 2025, one thing is undeniably clear: The era of "best efforts" for diversity in clinical trials is over.

It has been over 18 months since the release of the FDA's guidance on Diversity Action Plans (DAPs) in June 2024, moving the industry from recommendation to requirement. Driven by the Food and Drug Omnibus Reform Act (FDORA), these mandates now require sponsors to submit concrete, data-driven plans for enrolling underrepresented populations in Phase 3 and other pivotal studies.

For the past year, the message has been consistent: if your trial does not reflect the population that will use your drug, your data—and your approval—are at risk.

The 2026 Operational Challenge

For sponsors and CROs looking ahead to 2026, this remains more than just a regulatory checkbox; it is a significant operational challenge. The core question persists: How do you enroll diverse populations when traditional sites are often located far from the communities you need to reach?

The answer lies in robust digital infrastructure. Here is how Alethium’s platform helps you meet the guidance demands and turn compliance into an operational advantage.

1. Meeting the "Operational Measures" Standard

The FDA guidance explicitly calls for sponsors to implement "operational measures" that reduce the burden of participation. Traditional trials, which require frequent travel to academic medical centers, continue to disproportionately exclude working-class participants, caregivers, and those in rural areas.

The Alethium Solution: Decentralization by Design Alethium’s Televisits feature brings the trial directly to the participant. By enabling secure, device-agnostic video visits, you allow participants to join from their homes, effectively eliminating the travel barriers that drive dropout rates in underrepresented groups.

  • Any Device: No expensive hardware is required; participants can use their own smartphones.

  • Integrated Evidence: Capture photos and documents directly in the visit, ensuring data integrity without the need for a physical site visit.

2. Ensuring Global Reach and Language Access

A core component of the DAP ensures that language is not a barrier to entry. The FDA expects sponsors to provide trial materials in languages relevant to the trial population.

The Alethium Solution: Automation at a Global Scale Alethium’s Automation Framework is built for global deployment.

  • Multilingual Support: We support hundreds of languages, including complex scripts like Arabic and Hebrew, ensuring that eConsent and eCOA forms are fully accessible to non-English speakers.

  • Global Identity Verification: Our AI-driven identity proofing validates government IDs from 195+ countries, allowing you to securely enroll diverse populations globally while preventing fraud.

3. Tracking Data-Driven Enrollment Goals

Sponsors must set enrollment goals based on the epidemiology of the disease, not just census data. If a disease disproportionately affects a specific demographic, your trial must reflect that.

The Alethium Solution: Real-Time Visibility

You cannot manage what you cannot measure. Alethium’s Advanced Analytics draw directly from the event-driven audit log, giving you real-time visibility into enrollment demographics.

  • Course Correction: Detect under-enrollment trends in specific subgroups early, allowing you to adjust recruitment strategies before the trial timeline is jeopardized.

  • Audit-Ready: Every data point is traceable, providing the "immutable evidence" regulators require to prove you met your DAP commitments.

The Takeaway for 2026

The FDA’s Diversity Action Plan guidance was a call to modernize, and passive recruitment strategies are no longer sufficient. To succeed in the current regulatory landscape, you need a platform that actively dismantles barriers to entry.

Alethium provides the automated, decentralized, and secure infrastructure needed to turn diversity from a mandate into a reality.

Ready to align your 2026 trials with FDA diversity standards?

Book a demoto see how Alethium powers inclusive research.

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