Recent and imminent improvements to PAAB preclearance: Update on Accelerated Review Options (ARO) and the new submission formats

It has now been three months since PAAB launched the Accelerated Review Options (July 4, 2022).  During that time, 250 submissions have gone through the accelerated pathway. Approximately half of all manufacturers, and approximately half of all agencies that have submitted advertising on their behalf, have utilized the accelerated pathway. Over time, the PAAB will widen the range of APS types that are applicable to some of the ARO levels. But it is exciting to note that ARO submissions already represent almost 10% of PAAB’s total submission volume. 


The new submission formats (particularly minor updates and iterative submissions) have had tremendous uptake. Modular submissions have been used as well but to a lesser extent. Presumably, this forward-looking submission format will become more appealing over time. As advertising targeting/tailoring/generation increasingly becomes programmatically automated, we anticipate advertisers will leverage the agility of modular submissions.


Speaking of forward-looking, we are getting closer to launching the messenger functionality. This will give the manufacturer/agency the ability to receive rulings on pivotal copy and layout revisions while they are still working on revising other segments of the APS (i.e., while the APS is still on their end)! This should reduce the number of revisions to approval for APS containing particularly novel elements.


Usage of the upcoming messenger functionality will amplify the time savings already obtainable through ARO submissions. The combination of reduced time to first response, reduced time for revisions, and reduced number of rounds of revision should add up to a remarkable reduction in total time to approval. Stay tuned for the launch of the messenger functionality in the upcoming months.

October 6, 2022



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