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Are You Aloof About GDUFA? Managing Generic Drug User Fees in FY 2027

August 20, 2026 (2 min read)
Generic drug bottles moving through an automated packaging line, representing GDUFA facility and manufacturing fee obligations

Part 3 of the “Are You Aloof About OMUFA, MDUFA, and GDUFA?” series.

Final installment in a three-part series on FDA user fee programs. Part 1 covered OMUFA, Part 2 covered MDUFA, and this article focuses on GDUFA.

GDUFA Is More Than an ANDA Fee

The Abbreviated New Drug Application (ANDA) is only one part of GDUFA obligations.

GDUFA fees may also apply to:

  • ANDA submissions
  • Type II API Drug Master Files (DMFs)
  • Annual applicant program fees
  • API facilities
  • Finished dosage form (FDF) facilities
  • Contract manufacturing organizations (CMOs)

Because fees are tied to portfolios, affiliates, and facility listings—not just submissions—GDUFA is one of FDA’s most data-dependent user fee programs.

GDUFA III runs through September 30, 2027.

FY 2027 GDUFA Fees

Some fees increased (ANDA, DMF, applicant program), while most facility fees decreased. Each category must be evaluated independently for accurate forecasting.

Applicant Program Fee: Portfolio-Driven Risk

The annual applicant fee is based on total approved ANDAs held by a company and its affiliates:

A single ANDA can shift a company from $192K to $770K+.

FDA also aggregates ANDAs across affiliates, meaning ownership changes or corporate restructuring can directly impact fees—even without new submissions.

Discontinued ANDAs Still Count

Approved ANDAs remain in the fee calculation unless officially withdrawn. Companies should distinguish between:

  • Active ANDAs
  • Discontinued but approved ANDAs
  • Withdrawn ANDAs
  • Transferred ANDAs
  • Affiliate-held ANDAs

Failure to reconcile these categories can lead to underestimating the applicant fee tier.

Facility Fees: Status Matters More Than Activity

Facility fees are driven by FDA submission references, not current production status. A facility may still owe fees if it is:

  • Listed in an approved ANDA
  • Referenced for API or FDF manufacturing
  • Producing only for non-U.S. markets

Key classifications:

  • FDF vs API: dual-role facilities typically pay FDF fees
  • CMO status: depends on ownership and ANDA references
  • Packagers: may be fee-liable depending on role
  • Repackagers: generally not fee-liable
  • QC testing sites: not subject to facility fees

Stopping production does not automatically eliminate fee obligations—FDA records must be updated.

Foreign Facilities Pay More

For FY 2027, foreign facilities pay $15,000 more than domestic counterparts across API, FDF, and CMO categories.

Global manufacturers should ensure facility location and classification data are accurate to avoid budget errors.

Nonpayment Risks Extend Beyond Finance

If the applicant program fee is not paid within 20 days:

  • The company may be listed in arrears
  • FDA may refuse to receive ANDAs from the applicant and affiliates
  • Approved products may be deemed misbranded

GDUFA noncompliance can therefore affect both pipeline and marketed products.

FY 2027 GDUFA Readiness Checklist

Before FY 2027 begins:

  1. Reconcile approved ANDA portfolio (including discontinued products)
  2. Review affiliate relationships and ownership changes
  3. Confirm ANDA transfers and withdrawals in FDA records
  4. Map all API, FDF, CMO, packaging, and testing sites
  5. Validate facility classifications (domestic vs foreign, role-based)
  6. Budget each fee category separately
  7. Centralize payment and FDA documentation

Don’t Be Aloof About GDUFA

GDUFA fees are driven by interconnected regulatory data—not isolated submissions.

A single overlooked ANDA, outdated affiliate record, or misclassified facility can significantly change annual obligations.

Accurate, centralized regulatory data is the strongest defense against unexpected fees and compliance risk.

Take Control of Your GDUFA Exposure Before FY 2027

Across OMUFA, MDUFA, and GDUFA, one theme is consistent: FDA user fees are data and workflow challenges as much as financial ones.

LexisNexis Life Sciences Solutions can help you align ANDA portfolios, affiliate relationships, and facility data; improve fee forecasting; coordinate payment workflows; and maintain audit-ready records. Whether your team manages GDUFA activities in-house using our solutions or relies on our experts to support the process, we can help reduce compliance surprises and regulatory risk.

Contact us to strengthen your GDUFA user fee management process.

Editorial note: Fee figures are current as of August 13, 2026. Companies should confirm FDA updates and assess applicability to their specific portfolios and facilities before payment decisions.

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