February 2026
Complete Response Letter (CRL) received on February 13, 2026
Bitopertin received a Complete Response Letter from the FDA
Main objection related to the sufficiency of protoporphyrin IX (PPIX) as a surrogate biomarker, with the
FDA requesting to see the outcome of the ongoing APOLLO study before making a decision
Disc is committed to delivering bitopertin to patients and will focus on diligently completing the APOLLO study by Q4 2026 and responding to the FDA
November 2024 January 2025
July 2025
September 2025
October 2025
November 2025
EOP2
Meeting
Type C
Meeting
Pre-NDA
Meeting
NDA
Submitted
Awarded CNPV
NDA
Accepted
3
February 2026
CRL
Received
FDA indicated a need to see the results of the ongoing Phase 3 APOLLO study before making a decision
Accelerated approval relies on (1) whether there is evidence of an effect on the proposed surrogate endpoint (% change in whole blood metal-free PPIX) and (2) whether the proposed surrogate endpoint, including the magnitude of change, is reasonably likely to predict a clinical benefit
AURORA and BEACON provided sufficient evidence that bitopertin significantly lowers whole blood metal-free PPIX
Based on review of AURORA and BEACON results, FDA concluded that the trials did not show evidence of association between percent change in PPIX and sunlight exposure-based endpoints, as measured in the trials, despite the strong mechanistic and biological plausibility supporting the use of the PPIX biomarker in protoporphyria
FDA guided that for this application to be approved, Disc will need to provide additional evidence demonstrating the efficacy of bitopertin for the treatment of protoporphyria based on clinical endpoint(s)
Stated willingness to discuss options to meet this requirement, including completion and submission of results from the ongoing APOLLO trial
Other requests:
FDA requested that Disc provide a standard safety update as part of the resubmission
4
Disc will provide the new APOLLO safety data in the CRL response, which will be integrated with the prior safety database of over 4,000 subjects
PPIX Change:
% Change in WB PPIX
0
Bitopertin 60 mg
Sunlight Exposure:
Bitopertin 60 mg12
Tertiles of PPIX Change
-10
-20
-30
-40
-50
8
4
0
-4
0 2 4 6 8 10 12 14 16
Diff vs Placebo in
Pain-Free Sunlight Exposure (hr)
Light Tolerance Measure (Mean ± SD) | Tertile 1 (-89% to -38%) | Tertile 2 (-38% to -7%) | Tertile 3 (-7% to 190%) |
Cumulative total time in sunlight without pain (hr) | 161.1 ± 142.6 | 124.5 ± 68.3 | 117.5 ± 83.2 |
Average time in sunlight without pain (hr) | 1.61 ± 1.32 | 1.20 ± 0.72 | 1.16 ± 0.83 |
Change from baseline in time to prodrome (min) | 117.4 ± 148.6 | 109.4 ± 121.1 | 64.1 ± 123.8 |
Study Week
PPIX Decreased
PPIX Increased
Phototoxic Reactions
Placebo Bitopertin 60 mg
= Phototoxic Reaction = 2 Phototoxic Reactions
Treatment with bitopertin led to a 49% reduction in whole blood PPIX and 63% reduction in plasma PPIX vs placebo at month 4
PPIX reductions with bitopertin are similar to those seen in pregnant EPP patients and a photoinactivation study in which 30-50% reductions in PPIX led to marked improvements in light tolerance
CONFIDENTIAL
5
Closing enrollment in March; topline data expected Q4 2026
N Size | ~150 patients across sites in the US, Canada, Europe, and Australia |
Trial Duration | 6-month treatment period; Expected to fully enroll by March 2026 |
Trial Design | Randomized 1:1, double-blind, placebo-controlled |
Trial Population | EPP and XLP patients ages 12+, stratified by baseline light tolerance and geography |
Dose | 60 mg |
Co-primary Efficacy Endpoints |
metal-free PPIX after 6 months of treatment |
Additional Endpoints |
|
Robust Endpoint
Longitudinal analysis leverages robust model that demonstrated significance in AURORA
Accounts for time-dependent PPIX lowering effects with bitopertin and for waning of a placebo effect
Focuses efficacy on month 6, after PPIX is fully reduced and potential placebo effect is expected to have waned
Robust Study Design
Rigorous evaluation of baseline light tolerance required during screening and factored into analysis of the primary endpoint
Stratification by geography to minimize confounding factors affecting light exposure across study arms
Well-powered; blinded sample size recalculation completed in January 2026 with no change required
6
Co-primary Endpoints: Average Monthly Time in Light without Pain and PPIX Change from BaselineAURORA: Sunlight Tolerance Over Time†
AURORA: PPIX Over Time
p=0.03 vs PBO*
28
2-Week Aggregated Time (hr)
p=0.013 vs PBO*
24
20
16
12
1 3 5 7 9 11 13 15 17
20
% Change in WB PPIX
0
-20
-40
-60
0
15 29 43 71 121
Study Day
+8.1%
-21.5%
(p=0.004 vs PBO)
-41.7%
(p<0.001 vs PBO)
Placebo (n=24)
Week
Bitopertin 60 mg (n=25)
Placebo (n=24)
Bitopertin 20 mg (n=26) Bitopertin 60 mg (n=25)
* nominal p value
= last month of study = last 2-weeks of study
Longitudinal analysis demonstrated significance and was robust in AURORA
Accounts for time-dependent PPIX lowering effects with bitopertin and for waning of a placebo effect
Prespecified primary endpoint with consistent, high statistical significance in BEACON and AURORA
Recommended as co-primary by FDA, reflecting agency's
acknowledgement of the importance of lowering PPIX in EPP
† Post-hoc longitudinal analysis adjusted for baseline 7
Disc plans to respond to the CRL with data from the ongoing APOLLO trial
Expect to request Type A meeting with FDA to review our approach for resubmission Expect to complete enrollment in March 2026, several months ahead of guidance Expect to present topline data in Q4 2026 and use this data to submit a response to
the CRL
8
Typical FDA goal date for review of CRL response is ~6 months, implying potential for an updated decision by mid-2027
Disc's belief in the importance of bringing a potential disease modifying therapy to the EPP community and the potential for bitopertin to set a new standard of care in EPP has not changed
Disc has made every effort to bring bitopertin to the EPP community more quickly; while these efforts have not come to fruition, we remain committed to advancing the program and pursuing FDA approval of bitopertin
9
During this process, Disc is committed to providing continued access to bitopertin for current clinical trial participants
Program | Indication | 1H 2026 | 2H 2026 | 2027 |
Bitopertin Heme Synthesis Modulation | Erythropoietic Porphyrias (EPP & XLP) |
late 2026 |
| |
DISC-0974 Hepcidin Suppression | Anemia of Myelofibrosis (MF) |
|
| |
Anemia of Inflammatory Bowel Disease (IBD) |
|
| ||
DISC-3405 Hepcidin Induction | Polycythemia Vera (PV) |
|
| |
Sickle Cell Disease (SCD) |
|
|
Maintaining cash runway guidance into 2029
10
Q&A
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