CAR-T cell therapies and CD3-based bispecific T-cell engagers are moving from oncology into autoimmune indications such as lupus, myasthenia gravis and systemic sclerosis. Sponsors planning a first-in-human study in these diseases have to decide early who receives the first doses. That choice shapes the protocol, eligibility criteria, dose-escalation design, site selection and how the program is presented to FDA, EMA and national ethics committees and competent authorities.
The analysis below reviews early clinical programs for CAR-T and T-cell engager products in autoimmune disease and records whether they enrolled patients or healthy volunteers, along with the disease severity and treatment history required for entry. It then sets out what FDA, EMA, Health Canada, Japanese and other regulatory guidance says about population selection for cell and gene therapy, advanced therapy and first-in-human trials, and how that guidance applies to the autoimmune setting.
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Patients or healthy volunteers? First-in-human trials of CAR-T and T-cell engagers in autoimmune disease
Short answer
Every early clinical program we identified for CAR-T cells or CD3-based bispecific T-cell engagers (TCEs) in lupus, myasthenia gravis (MG) and systemic sclerosis (SSc) dosed patients, not healthy volunteers. Most restricted entry to patients with active, severe or treatment-refractory disease. An early five-patient series treated life-threatening, multi-drug-refractory SLE under a compassionate-use program 425. The registered phase 1 CAR-T and TCE trials in these indications all specify disease populations 153160161115121318390201208. We found no published or registered study in which a healthy volunteer received a CAR-T product or a TCE for an autoimmune indication 97319201208.
No FDA, EMA or national guidance document we reviewed addresses autoimmune CAR-T or TCE population selection by name. The patient-only approach follows from general cell and gene therapy, ATMP and first-in-human (FIH) guidance:
- FDA states that for most cellular and gene therapy trials "the benefit-risk profile is not acceptable for healthy volunteers" 264.
- EMA states that investigational ATMP trials are "usually conducted in patients, not healthy volunteers" 241.
- Health Canada says healthy-volunteer FIH trials of cell therapies "may be unethical" 41.
- Japan's regenerative medicine GCP guidance defaults to "patients with the disease or condition for which the investigational product is intended" 370.
- For bispecific antibodies, FDA says healthy volunteers "may not be appropriate" because of immunogenicity and toxicity 254.
What the early trials actually enrolled
CAR-T in systemic lupus erythematosus
- An early five-patient series. Five patients (median age 22) had life-threatening SLE, a median SLEDAI of 16, and disease refractory to several immunosuppressants. They received autologous anti-CD19 CAR-T cells (1×10^6/kg) after fludarabine and cyclophosphamide lymphodepletion under a compassionate-use program 425.
- First formal phase 1 data. A single-arm, multicentre phase 1 trial treated 13 patients with biopsy-confirmed class III to V lupus nephritis using a BCMA-CD19 compound CAR-T. One underdosed patient was recorded as compassionate use 430.
- Registered phase 1 programs consistently require refractory or active disease. Examples:
- Allogeneic products. Some programs use universal CAR-T derived from healthy donors. The donor is the cell source only; recipients are still patients with refractory SLE 156319.
CAR-T in myasthenia gravis
- Descartes-08 is an autologous BCMA-directed mRNA CAR-T. It was studied in a phase 1b/2a trial (MG-001, NCT04146051) that enrolled 14 adults with generalized MG and an MG-ADL score of 6 or higher. Phase 1b required MGFA class III to IV disease 417. It was then tested in a randomized, placebo-controlled phase 2b trial in 26 patients 420.
- No lymphodepletion. Descartes-08 was given without lymphodepletion chemotherapy, including outpatient dosing in phase 2b 417419. This lowers procedural risk, but the sponsor still enrolled only patients.
- Other phase 1 MG programs also enroll only patients, usually with refractory disease:
- CD19 CAR-T in refractory MG (Zhejiang University) 115
- BCMA CAR-T in refractory generalized MG with MGFA and MG-ADL/QMG thresholds 119124
- Arcellx's anito-cel dose escalation in generalized MG 121
- Novartis's YTB323 in treatment-resistant generalized MG 118
- A pediatric Descartes-08 study in juvenile MG 128
CAR-T in systemic sclerosis
- Industry phase 1/2 programs enroll adults with SSc. Kyverna's KYV-101 enrolls adults with SSc 3. Cabaletta's RESET-SSc (CABA-201) requires active disease 18.
- CASTLE basket trial. This phase 1/2a trial treated 9 treatment-resistant SSc patients with zorpocabtagene autoleucel after cyclophosphamide and fludarabine lymphodepletion 340.
- Pediatric and basket studies. A pediatric study targets childhood-onset refractory SSc 67. European basket studies enroll severe, treatment-failure systemic autoimmune disease 2016.
- Not every phase 1 study is first-in-human. The French CELL-ATTACK 1 study describes itself as "not first-in-human" 16. For regulators, "first in autoimmune disease" and "first in human" can be different questions.
Bispecific T-cell engagers
- A-319 (CD19×CD3). A phase 1 study in adults aged 18 to 60 with active/refractory SLE and positive autoantibodies. Healthy volunteers are not eligible 390393. Twelve active SLE patients have been reported from the intravenous arm, described as first in disease 58.
- Other registered phase 1 TCE studies also enroll only patients:
- Repurposed oncology TCEs. Early autoimmune use has come through compassionate or named-patient access in refractory patients, not formal FIH trials:
- A true FIH example. ABO2203, a lipid-nanoparticle mRNA encoding a CD19-targeting TCE, had its first-in-human study in three patients with refractory secondary immune thrombocytopenia 83.
Caveat on the registry data
Each registered CAR-T and TCE trial cited here sets the ClinicalTrials.gov healthy-volunteers flag to No, and each trial's stated population and eligibility text restricts entry to patients 201208. We also checked for CD3-bispecific studies in healthy participants for autoimmune indications. One immunology program (GSK3888130B, NCT05131971) dosed healthy participants, but the record does not identify it as a T-cell engager 295296.
What regulators say about the population choice
| Regulator | Document | Position relevant to autoimmune CAR-T / TCE FIH trials |
|---|---|---|
| FDA (CBER) | Considerations for the Design of Early-Phase Clinical Trials of Cellular and Gene Therapy Products (June 2015) | Healthy adults may be reasonable only for short-acting products or classes with a well-understood safety profile. For most CGT trials the benefit-risk is "not acceptable for healthy volunteers" because effects may be extended or permanent 264. |
| FDA (CBER) | Human Gene Therapy for Rare Diseases (January 2020) | "It is generally not acceptable to enroll normal, healthy volunteers into GT studies" 270. |
| FDA (CBER) | Human Gene Therapy Products Incorporating Human Genome Editing (January 2024) | FIH trials "generally should enroll only subjects for whom no other treatment options are available or justified," though less advanced disease may sometimes be appropriate 268. |
| FDA (CBER) | Considerations for the Development of CAR T Cell Products (January 2024) | Written for oncology. For non-oncology indications, sponsors should contact the Office of Therapeutic Products before the IND, for example at a pre-IND meeting 144. |
| FDA (CDER/CBER) | Bispecific Antibody Development Programs (May 2021) | Healthy volunteers may not be appropriate for initial trials of a bispecific because of immunogenicity and toxicity. Consider a MABEL-based starting dose for agonistic bispecifics 254. |
| EMA | Guideline on strategies to identify and mitigate risks for FIH and early clinical trials, Rev. 1 (2018) | No default either way. The choice is case by case, weighing whether toxicity is compatible with healthy-volunteer exposure, target presence in healthy people versus patients, variability, alternative treatments and therapeutic window 228. |
| EMA | Guideline on quality, non-clinical and clinical requirements for investigational ATMPs (July 2025) | ATMP trials are "usually conducted in patients, not healthy volunteers." FIH trials may begin in a subgroup with a more favourable benefit-risk and broaden later 241. |
| EMA | Guideline on medicinal products containing genetically modified cells, Rev. 1 (2021) | Early CAR-T development often targets late-stage or refractory disease. CRS, ICANS and B-cell depletion are important adverse reactions 237. |
| MHRA | FIH risk-mitigation guidance and Phase I accreditation scheme | Points to the CHMP first-in-human guideline for FIH risk factors 431. Defines "first time in patient" where giving the IMP to a healthy participant would be unethical or impossible 399. Higher-risk FIH trials may go to the CHM Clinical Trials, Biologicals and Vaccines Expert Advisory Group 406. |
| Health Canada | Preparation of Clinical Trial Applications for use of Cell Therapy Products in Humans | Traditional healthy-volunteer FIH trials "may be unethical." FIH trials are likely to enroll a subpopulation of intended patients 41. |
| MHLW/PMDA (Japan) | Guidance on the Ministerial Ordinance on GCP for Regenerative Medicine Products (amended December 2023) | "Unless otherwise specified, the trial should be conducted in patients with the disease or condition for which the investigational product is intended" 370. |
| Paul-Ehrlich-Institut (Germany) | CAR-T FAQ and hospital exemption pages | Autoimmune disease is described as a future application for CAR/T-cell therapies 309. Section 4b AMG hospital exemption allows individual-patient use of a non-routinely manufactured ATMP when the benefit-risk is favourable 310. The pages give no lupus-, MG- or SSc-specific position 309310. |
FDA
FDA's early-phase CGT guidance defines healthy volunteers as people who "do not have the disease or condition of interest." It limits their use to products with short duration of action or a well-characterized class safety profile 264. Autologous CAR-T cells, which persist and expand after infusion, do not fit either exception.
The same guidance cautions against assuming the sickest patients are the right FIH population. Limited physiologic reserve can make toxicity harder to tolerate, and disease-related events and concomitant therapies can confound interpretation. The sponsor must justify the chosen population in the IND 264265. If eligibility depends on failure of available therapy, the protocol should document that each patient's options were adequately evaluated 265267. This matters for autoimmune programs, where "refractory" is the most common entry criterion in the registered trials 153160115390.
For CAR-T outside oncology, FDA has not published population-specific recommendations. The 2024 CAR-T guidance directs non-oncology sponsors to pre-IND engagement with OTP 144. Its oncology stopping-rule examples, such as more than two Grade 4 CRS events in an FIH CAR-T study, show the level of safety oversight FDA expects 145.
For TCEs, the 2021 bispecific guidance pairs its caution on healthy volunteers with a recommendation to consider a MABEL-based FIH dose for agonistic constructs 254. FDA's 2023 immunotoxicity guidance adds that for immune-stimulating biopharmaceuticals, a MABEL or pharmacologically active dose may be more appropriate than a NOAEL-based dose 255. FDA's June 2026 draft on QSP-based MABEL dosing tells sponsors to choose the most conservative starting dose when estimates disagree. It allows a starting dose above absolute MABEL in life-threatening disease with justification and safeguards such as staggered enrollment 259.
EMA and the EU
EMA's revised FIH guideline sets no default population. It lists the factors that decide it, including whether toxicity can be justified in healthy volunteers and whether the target is present in healthy people as well as patients 228. The 2007 version named CD3 and CD28 "super-agonists," and cytokine cascades with potential for uncontrolled amplification, as modes of action needing special precautions 225.
For FIH trials that start in patients, the recommended starting dose is one expected to have minimal pharmacological effect while reflecting disease severity. EMA advises a single-ascending-dose design in the first patient cohort where healthy people and patients may differ 222.
The 2025 investigational ATMP guideline is the most direct EU statement. It says trials are usually conducted in patients and that the protocol must justify the population. Sponsors should consider disease burden, ability to tolerate adverse events, and prior and concomitant therapies 241. Staggered dosing, waiting periods and stopping rules from the general FIH guideline still apply to ATMPs 240233.
National regulators
- MHRA points sponsors to the CHMP first-in-human guideline for FIH risk factors 431. It gives patient-first trials their own label ("first time in patient") for cases where healthy-volunteer dosing would be unethical or impossible 399. FIH and ATMP trials are excluded from the UK's automatic authorisation route 395. Higher-risk FIH trials can be referred to the CTBVEAG 406.
- Health Canada cites the inherent risks of cell administration, including tumour formation, immunogenicity, inflammatory events and biodistribution. It expects longer-than-normal follow-up matched to the patient population 414245.
- Japan makes patient enrollment the default for regenerative medicine products, including gene-modified cell products 370. Its gene therapy guidance frames residual unknown risk as acceptable for seriously ill patients with limited conventional options 361.
- Germany's PEI confirms that the hospital exemption covers individual-patient ATMP use 310. In the pages reviewed, it does not describe specific approvals for autoimmune CAR-T 309310.
Why patient-only enrollment is the norm
The guidance and trial data give four connected reasons.
- Persistence and irreversibility. FDA's core objection to healthy volunteers in CGT trials is the risk of extended or permanent effects 264270. Autologous and allogeneic CAR-T products expand and persist, so their exposure cannot be treated as a time-limited drug exposure.
- The pharmacology is the toxicity. EMA lists B-cell depletion, alongside CRS and ICANS, as an important adverse reaction of CAR-T 237. The intended effect in autoimmune disease is deep B-cell or plasma-cell depletion. A healthy volunteer would take on the main adverse effect with no possible benefit.
- Procedure-related risk. Most autoimmune CAR-T protocols use fludarabine and cyclophosphamide lymphodepletion 425340. EMA requires that apheresis and lymphodepletion risks be assessed as part of the therapeutic intervention and captured in the safety database 241239. Descartes-08's lymphodepletion-free design reduces this burden, but it was still tested only in MG patients 417.
- Informative data. EMA's FIH guideline weighs whether the target and PK/PD behaviour in healthy people would represent the patient population 228394. B-cell reconstitution, autoantibody decline and disease activity can only be measured in patients.
For TCEs the reasoning is less absolute. FDA frames healthy-volunteer unsuitability as product-specific ("may not be appropriate") 254, and EMA's FIH guideline is explicitly case by case 228. In practice, every autoimmune TCE study we found enrolled patients, and the earliest access to repurposed oncology TCEs was compassionate use in refractory disease 3902012086473.
Practical implications for sponsors
- Justify the population explicitly. FDA expects the IND to explain why the chosen patients offer the best balance of risk, potential benefit and interpretable data. The most severe patients are not automatically the right choice 264265. EMA expects the same in the CTA 241.
- Engage early on non-oncology CAR-T. FDA's CAR-T guidance does not cover autoimmune indications and points sponsors to pre-IND discussion with OTP 144.
- Document "refractory" rigorously. When eligibility depends on failed standard therapy, protocols should record how each patient's alternatives were evaluated 267.
- Size the TCE starting dose conservatively. Use MABEL or a minimally pharmacologically active dose, supported by cytokine-release data 254255. Consider a single-ascending-dose first patient cohort 222397.
- Build ATMP-grade safeguards. Plan staggered dosing, waiting periods and stopping rules 240. Use predefined CRS/ICANS management algorithms and long-term follow-up 23745.
- Plan for national layers. These include UK expert-advisory referral for higher-risk FIH trials 406, Japan's patient default for regenerative products 370, and Germany's hospital-exemption route for individual-patient ATMP use 310.
Evidence gaps
- None of the regulatory documents reviewed discusses autoimmune CAR-T or TCE population selection by name. The positions above apply general CGT, ATMP, bispecific and FIH guidance to this setting.
- This article does not draw on agency-specific feedback on individual programs, such as pre-IND minutes, EMA scientific advice or CTA assessment reports.
- The only published SSc CAR-T data cited here are from the CASTLE basket trial 340. Earlier compassionate-use SSc case reports are not covered.