Next issueIssue 23 · Tue 17 Nov 

Issue 22

EMBRACE has halted in every EU country where it started.

CTIS logs a temporary halt for the HLP003 Phase 3 in Poland, Greece and Ireland, dated 28 September, the day recruitment ended. The sponsor's justification: "Temporary interruption in IP supply, not quality related". Our call: no restart by 31 March.

Lead Story

EMBRACE, the HLP003 Phase 3 in major depressive disorderMajor depressive disorder, or MDD, is the clinical diagnosis of depression itself, the broad population from which treatment-resistant depression is drawn once two adequate courses of antidepressants have failed., has logged a temporary halt in Poland, Greece and Ireland. Those are the three EU member states where it had started. In each, the halt is dated 28 September 2026. So is the end of recruitment.

The record is on CTISThe Clinical Trials Information System, or CTIS, is the European Union's single portal for applying to run a clinical trial and for publishing it, and each record lists the member states whose regulator has taken a decision on the trial and the sites in each., the EU's clinical trial register, number 2024-519270-40-00, sponsor Cybin IRL Limited. HLP003 is the drug the trial records still call CYB003.

Each of the three states lists four events: START_OF_TRIAL, START_OF_RECRUITMENT, END_OF_RECRUITMENT, TEMPORARY_HALT. Recruitment started on 2 March in Greece, 19 March in Ireland and 26 March in Poland. It ended in all three on 28 September.

Each halt carries the same reason, "Medicinal Product related", and the same sponsor justification, in full: "Temporary interruption in IP supply, not quality related". Elsewhere the record uses IP for the trial drug set against placebo: "2 administrations of 8 mg IP, 16 mg IP, or placebo".

Three more fields read the same on each halt: isTreatmentStopped false, isBenefitRiskBalanceChange false, subjectsStillReceivingTreatment 0.

The three notifications were submitted on 6 November. That is 39 days after the halt date. CTIS published the updated record on 7 November.

Czechia and Germany are on the record too, with first decisions dated 23 January 2026 and 20 November 2025, and no events at all.

ClinicalTrials.gov, the US register, still lists EMBRACE, NCT06793397, as RECRUITING. Its primary completion date is still 7 June 2027, last updated 2 November. That date is call 17, and call 17 reads that field alone.

What is not established: which supply was interrupted, and why recruitment ended on the day of the halt.

The concession: the sponsor wrote "temporary", and nothing on the record says otherwise.

Our view: in these three states the halt reads as a wind-down, not a pause. That is this week's call.

Compass

Update, 10 November. Issue 21 said: "Compass has not filed Q3 results as of 2 November." That was true on 2 November. It was out of date by the time Issue 21 went out, at 17:30 UTC on 3 November. Compass's quarterly report, the 10-Q, was accepted by the SEC at 13:07 UTC that day, 4 hours 22 minutes before our send. The results release followed in an 8-K at 13:22 UTC.

The release says Compass's New Drug ApplicationA New Drug Application, or NDA, is the filing a company makes to the US Food and Drug Administration asking permission to sell a medicine, and it is the only marketing application Compass Pathways has said it is preparing for COMP360. (NDA) for COMP360, the US marketing application, is almost done. In its words: "Final NDA submission nearing completion and will be filed in the next two weeks". Two weeks from 3 November is 17 November. That is our arithmetic, not a Compass date.

Compass guides launch in the first half of 2027, subject to FDA approval. Cash at 30 September: $444.0 million.

The release does not mention Europe, the European Medicines AgencyThe European Medicines Agency, or EMA, is the European Union's central medicines regulator: through the centralised procedure it evaluates whether a medicine may be sold across the EU and EEA, and it has no say in what any country then pays for it. (EMA) or the MHRA, the UK medicines regulator. The 10-Q says: "We have not previously completed the submission of a new drug application, or NDA, to the FDA, or a marketing authorization application, or MAA, to the EMA or the MHRA, and have not obtained regulatory approval for COMP360."

Helus

Helus Pharma, formerly Cybin Inc., filed a material change report dated 5 November. Co-founders Eric So and Paul Glavine stepped down from their executive and consulting roles effective 26 October, announced 27 October. They stay on the board.

Helus guides topline from APPROACH, its other HLP003 Phase 3, for Q4 2026. No Helus filing carries one. Its chief executive, Michael Halstead, was scheduled for a fireside chat at Guggenheim's healthcare conference in Boston on 9 November. Helus has filed nothing with the SEC since 6 November.

Ledger

Call 17 holds: NCT06793397 still gives primary completion 7 June 2027.

Calls 9 and 16, checked in SEC filings as Issue 21 said they would be. Call 9: the Q3 10-Q discloses no application to the EMA or the MHRA. Call 16: Compass says the final NDA submission "will be filed in the next two weeks", and it has filed nothing with the SEC since 3 November.

The board: three hits, two misses, one void, fifteen open.

Fifteen carried in; this issue makes the sixteenth.

The call

Call 22: EMBRACE will not restart in Poland, Greece or Ireland by 31 March 2027.

Recruitment ended the day the trial halted, in all three, and the halts were notified 39 days later. We think none restarts by March.

Falsifier: CTIS shows RESTART_OF_TRIAL or RESTART_OF_RECRUITMENT for Poland, Greece or Ireland on record 2024-519270-40-00, with an event date on or before 31 March 2027, as published in CTIS when read on 30 April 2027.

Resolves 2027-03-31, scored on the record as published on 30 April 2027, in the first May issue.

Corrections

Correction, 10 November 2026, Issue 20. The clause at issue is in the contingent value rightA contingent value right, or CVR, is a promise by a buyer to pay the sellers a further sum only if a named event happens by a named date, so the headline price of a deal that carries one is a ceiling and not a payment. (CVR) from Lilly's purchase of AtaiBeckley. It turns on three indications: treatment-resistant depressionTreatment-resistant depression, usually shortened to TRD, is major depressive disorder that has not meaningfully improved despite adequate doses of at least two different antidepressants, each taken for long enough and with adherence confirmed, which is the European Medicines Agency's definition rather than a universal one. (TRD), major depressive disorder (MDD) and generalised anxiety disorderGeneralised anxiety disorder, or GAD, is persistent and excessive worry that the person cannot control, and it is the indication in which Definium ran its two Phase 3 trials and one of the three Qualifying Indications in the AtaiBeckley CVR agreement. (GAD). Issue 20 said: "If Lilly ends VLS-01 development in TRD and starts MDD or GAD, the exclusion moves to TRD instead." Precisely: under Section 4.3(a) of the form of CVR agreement, TRD is deemed excluded instead of the indication Lilly starts; the other of MDD or GAD stays excluded. Exhibit 01 carries the same correction, dated 5 November.

Referenced

Built from this issue's own tags, the row ids in its header and the registry numbers it cites. The text above is unchanged from the issue as sent.

Assets
HLP003

Sources

Lead

Compass

Helus

The call

Corrections