Disc Medicine, Inc.NASDAQ: IRON

Bitopertin Regulatory Update

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Bitopertin Regulatory Update

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

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    • 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

Demonstrated reductions in PPIX and improvements in clinical metrics

PPIX Change:

% Change in WB PPIX

0

Bitopertin 60 mg

Sunlight Exposure:

Bitopertin 60 mg

12

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

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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

  • Average monthly total time in sunlight without pain between 10:00 and 18:00 during the last month of the 6-month treatment period

  • Percent change from baseline in whole blood

metal-free PPIX after 6 months of treatment

Additional Endpoints

  • Occurrence of phototoxic reactions

  • Cumulative total pain-free time in sunlight

  • Change from baseline in time to prodrome

  • Patient global impression of change (PGIC)

  • Safety and tolerability

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

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Co-primary Endpoints: Average Monthly Time in Light without Pain and PPIX Change from Baseline

AURORA: 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

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  • During this process, Disc is committed to providing continued access to bitopertin for current clinical trial participants

Disc is well-capitalized through APOLLO readout and additional key pipeline milestones

Program

Indication

1H 2026

2H 2026

2027

Bitopertin Heme Synthesis Modulation

Erythropoietic Porphyrias (EPP & XLP)

  • APOLLO topline - Q4 2026

  • Submit response to CRL -

late 2026

  • FDA decision mid-2027

  • Ex-US regulatory submissions

DISC-0974

Hepcidin Suppression

Anemia of Myelofibrosis (MF)

  • Topline RALLY-MF Phase 2 data

  • End of Phase 2 Meeting

  • Phase 3 initiation

Anemia of Inflammatory Bowel Disease (IBD)

  • RALLY-IBD Phase 2 initiation

  • RALLY-IBD Phase 2 Data

DISC-3405

Hepcidin Induction

Polycythemia Vera (PV)

  • Initial RESTORE-PV Phase 2 Data

  • Topline RESTORE-PV Phase 2 Data

  • End of Phase 2 Meeting and Phase 3 initiation

Sickle Cell Disease (SCD)

  • Initial Phase 1b Data

  • Topline Phase 1b data

  • Phase 2 initiation

Maintaining cash runway guidance into 2029

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Q&A
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