Drug-Induced Kidney Injury: Renal Safety Assessment in Clinical Development and Pharmacovigilance
- Drug-Induced Kidney Injury: Renal Safety Assessment in Clinical Development and Pharmacovigilance
- Introduction
- Learning Objectives
- Understanding Drug-Induced Kidney Injury
- Kidney Function Versus Kidney Injury
- Serum Creatinine and eGFR
- Cystatin C and Alternative Measures of Kidney Function
- Urine Output
- Proteinuria and Albuminuria
- Patterns of Drug-Induced Kidney Injury
- Renal Safety Biomarkers
- The Problem of Pseudo-Nephrotoxicity
- Medical Evaluation of a Potential Drug-Induced Kidney Injury Case
- Kidney Safety in Clinical Development
- FDA Targeted Kidney Safety Analyses
- Post-Marketing Pharmacovigilance
- Worked Examples
- Limitations of Renal Safety Assessment
- Practical Medical Review Framework
- Pharmacovigilance and Inspection Considerations
- Common Mistakes in Renal Safety Assessment
- What an Experienced Safety Physician Looks For
- Kidney Safety Compared With Liver Safety
- Key Takeaways
- References
Introduction
The kidneys are major targets for drug-related toxicity because they receive a high proportion of cardiac output, concentrate substances during urine formation and contain specialized cellular transport systems that can expose renal tissues to relatively high concentrations of medicines and their metabolites.
Drug-induced kidney injury can therefore arise through multiple mechanisms. These include direct tubular toxicity, glomerular injury, interstitial inflammation, crystal deposition, obstruction, vascular injury and changes in renal haemodynamics.
Renal safety assessment is consequently more complicated than simply monitoring serum creatinine.
Serum creatinine is an important marker of kidney function, but a change in serum creatinine does not necessarily mean that structural kidney injury has occurred. Conversely, clinically important kidney injury can sometimes occur before a substantial change in serum creatinine becomes apparent.
This distinction is central to renal safety assessment.
A drug may produce a reversible functional change in renal filtration without causing structural injury. Another drug may cause tubular cellular injury while the measurable decline in kidney function is initially small.
For pharmacovigilance professionals, the important question is therefore not simply:
"Did creatinine increase?"
It is:
"What happened to kidney function, is there evidence of kidney injury, what mechanism is most plausible, and is the medicinal product responsible?"
This article describes the principles used to answer those questions during clinical development and post-marketing pharmacovigilance.
The approach is complementary to the assessment of other organ toxicities such as drug-induced liver injury. However, there is no single universally accepted renal equivalent of Hy's Law.
Instead, renal safety assessment integrates measures of kidney function, structural injury, urine findings, clinical events, exposure, competing causes and, where appropriate, emerging biomarkers.
Learning Objectives
After reading this article, the reader should be able to:
- explain why the kidney is vulnerable to drug-induced injury;
- distinguish kidney function from structural kidney injury;
- describe the role and limitations of serum creatinine;
- explain the role of eGFR and cystatin C;
- understand the clinical importance of urine output;
- describe the use of proteinuria and albuminuria in renal safety assessment;
- explain the principal patterns of drug-induced kidney injury;
- distinguish tubular, glomerular, interstitial, vascular and obstructive injury;
- describe the role of renal injury biomarkers;
- explain the significance of KIM-1, NGAL, cystatin C and related biomarkers;
- understand the problem of pseudo-nephrotoxicity;
- describe how potential renal safety signals are evaluated in clinical trials;
- understand the FDA approach to targeted kidney safety analyses;
- apply renal safety principles to post-marketing pharmacovigilance;
- identify common mistakes in the assessment of potential drug-induced kidney injury;
- understand what an experienced safety physician looks for when evaluating a renal safety signal.
Understanding Drug-Induced Kidney Injury
What Is Drug-Induced Kidney Injury?
Drug-induced kidney injury refers to impairment or damage to the kidneys caused by exposure to a medicinal product.
The term encompasses several biological processes.
A drug can alter renal function without directly damaging renal cells.
A drug can also produce structural injury that eventually leads to impaired kidney function.
The clinical presentation can therefore range from a small laboratory abnormality to severe acute kidney injury requiring kidney replacement therapy.
Potential manifestations include:
- increased serum creatinine;
- reduced estimated glomerular filtration rate;
- reduced urine output;
- proteinuria;
- albuminuria;
- haematuria;
- electrolyte abnormalities;
- acid-base abnormalities;
- tubular dysfunction;
- acute interstitial nephritis;
- glomerular disease;
- acute tubular injury;
- renal failure.
The same laboratory abnormality can arise through very different mechanisms.
An increase in serum creatinine, for example, can result from reduced glomerular filtration, altered tubular secretion of creatinine, changes in creatinine production or other non-structural mechanisms.
The medical evaluation must therefore establish the likely mechanism rather than treating every laboratory change as structural nephrotoxicity.
Why the Kidney Is Vulnerable to Drug Toxicity
The kidneys perform several functions that make them susceptible to drug-related effects.
They receive substantial renal blood flow.
They filter large volumes of plasma.
They actively secrete and reabsorb many substances.
They concentrate certain compounds within the tubular fluid.
Renal epithelial cells also contain transporters and metabolic systems that can influence intracellular exposure to drugs and metabolites.
Consequently, potentially toxic substances may reach concentrations within particular nephron segments that are substantially different from their concentrations in systemic circulation.
Different drugs can therefore injure different parts of the nephron.
This produces different clinical phenotypes.
Mechanisms of Drug-Induced Kidney Injury
Drug-induced kidney injury can arise through several broad mechanisms:
- direct tubular toxicity;
- glomerular injury;
- acute interstitial nephritis;
- altered renal haemodynamics;
- vascular injury;
- crystal nephropathy;
- obstructive nephropathy;
- electrolyte-mediated injury;
- immune-mediated injury;
- secondary injury from systemic toxicity.
A single medicine may also produce more than one mechanism depending on dose, duration, patient characteristics and concomitant treatments.
Understanding mechanism is therefore an important part of medical causality assessment.
Kidney Function Versus Kidney Injury
The Fundamental Distinction
The most important concept in renal safety assessment is the distinction between kidney function and kidney injury.
Kidney function describes how effectively the kidneys perform functions such as filtration and regulation of fluid and electrolytes.
Kidney injury refers to structural or cellular damage.
These concepts overlap but are not identical.
A patient can have evidence of kidney injury before a major decline in filtration occurs.
Conversely, kidney function can change without structural kidney damage.
This distinction explains why serum creatinine alone cannot provide a complete picture of renal safety.
Functional Changes Without Structural Injury
Some medicines alter renal haemodynamics.
For example, a drug can reduce glomerular filtration through a change in intrarenal haemodynamics without causing direct tubular cell death.
Other medicines can alter the tubular secretion of creatinine.
The resulting increase in serum creatinine may appear similar to an injury-related increase even though the underlying mechanism is different.
This is sometimes described as pseudo-nephrotoxicity or a creatinine-based apparent decline in renal function without corresponding structural injury.
The distinction is particularly important during drug development because an apparent renal safety signal can otherwise be misclassified.
Structural Injury Without an Immediate Large Functional Change
The reverse situation is also possible.
Tubular cellular injury may occur before sufficient functional loss develops to produce a large serum creatinine increase.
This is one reason why renal injury biomarkers have attracted interest in clinical development.
A biomarker that reflects cellular stress or injury may potentially provide information that differs from a conventional filtration marker.
However, biomarkers should not automatically be interpreted as diagnostic proof of clinically meaningful drug-induced kidney injury.
Their interpretation depends on the biomarker, indication, assay, timing, clinical context and regulatory status.
Serum Creatinine and eGFR
Serum Creatinine
Serum creatinine remains one of the most important conventional markers used in renal safety assessment.
Creatinine is produced from creatine metabolism and is eliminated predominantly through the kidneys.
When glomerular filtration decreases, serum creatinine generally increases.
However, serum creatinine is influenced by factors other than kidney filtration.
These include:
- muscle mass;
- age;
- sex;
- diet;
- creatinine production;
- volume status;
- certain medicines;
- tubular secretion;
- laboratory measurement.
Therefore, a change in serum creatinine should be interpreted in clinical context.
Why Serum Creatinine Is an Imperfect Injury Marker
Serum creatinine is primarily a marker of kidney function rather than a direct marker of cellular injury.
It may change relatively late in the course of kidney injury.
The relationship between serum creatinine and filtration is also not instantaneous.
A patient can therefore have meaningful renal injury before serum creatinine reaches a predefined threshold.
This limitation has been one of the major drivers for the development and evaluation of additional renal biomarkers.
Estimated Glomerular Filtration Rate
eGFR provides an estimate of glomerular filtration based on serum creatinine and other demographic or laboratory variables, depending on the equation used.
eGFR is useful for describing baseline kidney function and chronic kidney disease.
However, rapidly changing kidney function creates challenges for interpreting eGFR because conventional equations generally assume a relatively stable creatinine concentration.
For acute changes, the absolute serum creatinine trajectory and clinical context may therefore be more informative than treating a calculated eGFR value as a precise real-time measurement of filtration.
Baseline Kidney Function
Baseline renal function is essential for interpreting a potential drug-related change. [7]
A clinical-trial subject may enter a study with:
- normal kidney function;
- chronic kidney disease;
- diabetic kidney disease;
- proteinuria;
- reduced eGFR;
- previous acute kidney injury;
- a history of nephrotoxic exposure.
The same absolute creatinine value can have different clinical implications depending on baseline status.
Longitudinal baseline information can therefore be more informative than a single screening result.
Cystatin C and Alternative Measures of Kidney Function
Cystatin C
Cystatin C is a low-molecular-weight protein produced by nucleated cells and filtered by the glomerulus.
Because its biological determinants differ from those of creatinine, cystatin C can provide complementary information about kidney filtration.
It can be particularly useful when serum creatinine is potentially misleading.
The 2026 KDIGO AKI/AKD public-review draft includes serum cystatin C within its proposed framework for identifying AKI and suggests using it when serum creatinine is less accurate.
Because this is a public-review draft rather than a finalized guideline, its recommendations should be described accordingly.
When Alternative Markers May Help
Alternative markers may be particularly useful when creatinine production is unusual or when creatinine-based estimates are difficult to interpret.
Examples include patients with:
- very low or high muscle mass;
- certain chronic illnesses;
- substantial changes in body composition;
- conditions affecting creatinine generation;
- medications affecting creatinine handling.
No alternative biomarker should be interpreted in isolation.
The objective is to improve the characterization of kidney function and injury rather than to replace clinical assessment with a single laboratory result.
Urine Output
Why Urine Output Matters
Urine output provides a different dimension of renal function from serum biomarkers.
A substantial reduction in urine output can indicate acute deterioration in kidney function even before serum creatinine has changed substantially.
Urine output can also provide information about the severity and clinical trajectory of an acute kidney injury episode.
However, urine output is influenced by:
- fluid administration;
- diuretic therapy;
- obstruction;
- hydration;
- hemodynamics;
- measurement accuracy;
- clinical circumstances.
Therefore, it must also be interpreted in context.
Acute Kidney Injury Criteria
KDIGO criteria have historically defined AKI using changes in serum creatinine and urine output. [5]
The 2026 KDIGO public-review draft proposes an expanded framework incorporating functional and structural criteria and includes serum creatinine, cystatin C, urine output and qualified kidney-damage biomarkers. [6]
Because the 2026 document remains a draft, safety professionals should verify which criteria are specified by the relevant clinical protocol, regulatory analysis plan or medical-review framework.
The broader principle remains unchanged:
AKI is a clinical syndrome defined by a change in kidney function and/or evidence of kidney injury over a defined time period, rather than by one isolated laboratory value.
Proteinuria and Albuminuria
Proteinuria
Proteinuria refers to increased urinary protein excretion.
It can occur through several mechanisms.
Proteinuria may reflect:
- glomerular injury;
- tubular dysfunction;
- overflow proteinuria;
- transient physiological changes;
- systemic disease.
The type and magnitude of proteinuria therefore matter.
Albuminuria
Albuminuria is particularly informative for glomerular barrier abnormalities.
Increased urinary albumin can indicate altered glomerular permeability.
However, albuminuria can also be influenced by:
- diabetes;
- hypertension;
- exercise;
- infection;
- underlying kidney disease;
- other systemic conditions.
Consequently, a treatment-emergent increase in albuminuria should be evaluated against baseline and clinical context.
Why Urinary Protein Can Complement Serum Creatinine
Serum creatinine primarily describes filtration.
Urinary protein and albumin provide information about the integrity and function of the nephron and glomerular filtration barrier.
A patient may therefore develop significant proteinuria without an immediate major increase in serum creatinine.
This is particularly important for medicines associated with glomerular injury.
Patterns of Drug-Induced Kidney Injury
Tubular Injury
The renal tubules are important targets for drug toxicity. [8]
Tubular injury can result from:
- direct cellular toxicity;
- accumulation of drugs or metabolites;
- oxidative stress;
- mitochondrial injury;
- transporter-mediated exposure;
- crystal formation.
Clinical manifestations can include:
- rising serum creatinine;
- electrolyte abnormalities;
- glycosuria;
- proteinuria;
- acid-base abnormalities;
- reduced concentrating ability.
The specific pattern depends on the nephron segment affected.
Glomerular Injury
Glomerular injury affects the filtration barrier.
Potential manifestations include:
- albuminuria;
- proteinuria;
- haematuria;
- oedema;
- reduced serum albumin;
- nephrotic or nephritic syndromes.
Glomerular injury may require specialist evaluation because the causal mechanisms and clinical consequences differ substantially from tubular toxicity.
Acute Interstitial Nephritis
Acute interstitial nephritis is an inflammatory injury involving the renal interstitium and tubules.
Medicines are an important cause.
Potential features include:
- rising serum creatinine;
- pyuria;
- haematuria;
- systemic symptoms;
- rash;
- fever;
- eosinophilia.
The classic triad is not present in every patient.
Therefore, absence of rash, fever or eosinophilia does not exclude drug-induced interstitial nephritis.
Hemodynamic Kidney Injury
Some medicines can alter renal blood flow or intraglomerular pressure.
The resulting reduction in filtration may produce an increase in serum creatinine without direct structural toxicity.
This distinction is important because the clinical implications and management can differ from those of direct tubular injury.
Vascular Injury
Drug-related vascular effects can produce renal injury through:
- thrombotic microangiopathy;
- vasoconstriction;
- endothelial injury;
- hypertension;
- ischemia.
The renal findings may occur together with abnormalities in other organ systems.
Crystal and Obstructive Nephropathy
Some medicines or metabolites can precipitate within the urinary tract.
This can cause:
- tubular obstruction;
- interstitial injury;
- renal colic;
- haematuria;
- acute kidney injury.
Imaging and urine findings can be particularly useful in evaluating these mechanisms.
Renal Safety Biomarkers
Why Biomarkers Are Needed
The limitations of serum creatinine have encouraged the development and evaluation of biomarkers that may detect kidney injury earlier or provide mechanistic information.
FDA has supported exploratory development of urinary biomarkers for drug-induced renal tubular injury, including:
- alpha-glutathione S-transferase;
- clusterin;
- cystatin C;
- kidney injury molecule-1;
- neutrophil gelatinase-associated lipocalin;
- osteopontin;
- urinary albumin;
- urinary total protein.
These biomarkers should be understood as complementary tools.
FDA's Letter of Support describes their exploratory use in early clinical development and emphasizes that they should be interpreted alongside traditional renal safety measures and other clinical and nonclinical findings.
Kidney Injury Molecule-1
Kidney Injury Molecule-1, or KIM-1, is associated with renal tubular injury, particularly proximal tubular injury.
Urinary KIM-1 has therefore attracted substantial interest as a marker of tubular injury.
Its potential value is that it may provide information about cellular injury that differs from serum creatinine.
However, detection of an elevated biomarker does not automatically establish that a medicinal product has caused clinically important kidney injury.
NGAL
Neutrophil gelatinase-associated lipocalin, or NGAL, can increase in association with kidney injury.
NGAL has been studied extensively as an early marker of tubular injury.
However, NGAL can also be influenced by conditions outside a narrowly defined drug-induced tubular injury phenotype.
Its interpretation therefore requires clinical context.
Cystatin C
Cystatin C can be used as a marker of kidney filtration and may provide complementary information to creatinine.
Urinary cystatin C has also been studied as a marker of tubular dysfunction.
These are conceptually different uses and should not be conflated.
Clusterin, NAG and Other Biomarkers
Other biomarkers investigated in renal safety include:
- clusterin;
- N-acetyl-beta-D-glucosaminidase;
- osteopontin;
- alpha-GST.
Different biomarkers may reflect different nephron segments or mechanisms of cellular stress.
A biomarker panel can therefore potentially provide more information than one biomarker alone.
However, biomarker panels introduce additional analytical, interpretative and regulatory considerations.
Biomarker Qualification Versus Exploratory Use
One of the most important distinctions for pharmacovigilance professionals is between:
- a routinely established clinical laboratory marker;
- an exploratory biomarker;
- a biomarker with a Letter of Support;
- a qualified biomarker for a defined context of use.
These categories should not be treated as interchangeable.
FDA's Letter of Support for the renal biomarker panel explicitly encouraged exploratory use and noted that the performance characteristics and sensitivity and specificity of the biomarkers were not fully established for broad nephrotoxicity detection.
Therefore, an article about renal biomarkers should avoid describing every candidate biomarker as a validated diagnostic test for drug-induced kidney injury.
The Problem of Pseudo-Nephrotoxicity
Creatinine Transporter Effects
Some drugs can increase serum creatinine by interfering with renal tubular secretion of creatinine.
This can create the appearance of reduced kidney function without structural kidney injury.
The distinction is important because an apparent decline in eGFR may otherwise be misclassified as nephrotoxicity.
Why This Matters in Clinical Trials
If a drug causes a reversible creatinine increase through transporter inhibition, the clinical-development team may observe:
- increased serum creatinine;
- reduced creatinine-based eGFR;
- no corresponding injury biomarker increase;
- no clinical features of kidney damage;
- stability or change in cystatin C that does not support the same mechanism.
The total pattern may therefore suggest a functional or pharmacological effect rather than structural renal injury.
This is one reason why FDA's Kidney Injury Targeted Analysis Guide recommends considering additional data such as proteinuria, albuminuria and cystatin C when evaluating potential renal signals.
Hemodynamic Effects
A similar issue arises when a medicine changes renal haemodynamics.
The resulting reduction in filtration may be pharmacologically expected rather than evidence of direct tubular toxicity.
This does not mean that the effect is clinically irrelevant.
A functional change can still be important in patients with limited renal reserve or when combined with other nephrotoxic exposures.
The correct conclusion is therefore not simply "not nephrotoxic."
The reviewer should characterize the mechanism and clinical significance accurately.
Medical Evaluation of a Potential Drug-Induced Kidney Injury Case
Confirm the Laboratory Data
The first step is to confirm:
- serum creatinine;
- baseline creatinine;
- eGFR;
- urine output where available;
- proteinuria;
- albuminuria;
- relevant electrolytes;
- other available renal biomarkers.
Laboratory reference ranges and units should also be confirmed.
Establish the Time Course
The reviewer should determine:
- treatment start date;
- dose changes;
- onset of renal abnormality;
- peak abnormality;
- treatment interruption;
- recovery;
- rechallenge if it occurred;
- exposure to other potentially nephrotoxic medicines.
Temporal association is necessary for many causality assessments but does not establish causality by itself.
Review Baseline Kidney Status
The reviewer should determine whether the subject had:
- chronic kidney disease;
- diabetes;
- hypertension;
- proteinuria;
- previous AKI;
- renal disease;
- previous nephrotoxic exposure.
The baseline should ideally include more than one measurement when renal function is known to fluctuate.
Review Concomitant Medicines
Potentially nephrotoxic or renal-function-altering medicines should be considered.
The review may include:
- NSAIDs;
- renin-angiotensin system inhibitors;
- diuretics;
- antimicrobials;
- antineoplastic agents;
- contrast agents;
- immunosuppressants;
- other medicines with known renal effects.
The purpose is not to label every concomitant medicine as causal.
The purpose is to determine whether another exposure provides a more plausible explanation.
Evaluate Volume and Hemodynamic Status
The reviewer should consider:
- dehydration;
- vomiting;
- diarrhoea;
- hypotension;
- sepsis;
- heart failure;
- fluid overload;
- recent surgery;
- intensive-care exposure.
These factors can materially affect renal function.
Evaluate the Urine
Where available, review:
- urine output;
- urinalysis;
- proteinuria;
- albuminuria;
- haematuria;
- pyuria;
- urinary sediment.
The pattern can provide important clues about the underlying mechanism.
Consider Imaging
Imaging may be appropriate when obstruction, stones or other structural abnormalities are suspected.
Renal ultrasound and other imaging modalities can help distinguish obstructive or structural causes from purely functional changes.
Assess Dechallenge
Improvement after drug discontinuation can support a causal relationship.
However, the interpretation depends on:
- expected recovery time;
- renal reserve;
- concomitant interventions;
- competing causes;
- whether the drug has a long half-life;
- whether kidney replacement therapy occurred.
Assess Rechallenge
A recurrence after re-exposure may provide strong causal evidence.
However, deliberate rechallenge is generally inappropriate when a serious renal reaction could recur.
An inadvertent or clinically necessary rechallenge should be documented and evaluated carefully.
Kidney Safety in Clinical Development
Individual-Subject Review
Individual subjects may require medical review when they develop:
- clinically important creatinine increases;
- AKI;
- substantial proteinuria;
- marked albuminuria;
- unusual urine findings;
- renal adverse events;
- renal injury biomarker changes.
The medical reviewer should integrate laboratory, clinical and treatment information.
Population-Level Review
At the population level, clinical-development teams may examine [2]:
- mean and median creatinine changes;
- maximum creatinine;
- shifts from baseline;
- eGFR changes;
- AKI events;
- urine-output abnormalities;
- proteinuria;
- albuminuria;
- treatment discontinuations;
- hospitalization;
- kidney replacement therapy;
- treatment-group differences.
The purpose is to determine whether there is a consistent treatment-related pattern.
Treatment Versus Control
A renal laboratory abnormality occurring in both treatment and control groups may have a different interpretation from an abnormality concentrated in the investigational treatment group.
The reviewer should consider:
- comparator;
- baseline risk;
- exposure duration;
- monitoring frequency;
- concomitant medication;
- underlying disease;
- patient population.
Control data are therefore essential for interpreting population-level renal signals.
Exposure-Response Assessment
If renal abnormalities increase with increasing exposure, this may support a drug-related mechanism.
Exposure-response assessment can be particularly informative when:
- the drug has known renal pharmacology;
- the effect is reversible;
- the signal is concentrated at higher exposures;
- a pharmacodynamic mechanism is plausible.
However, exposure-response association does not by itself prove structural nephrotoxicity.
FDA Targeted Kidney Safety Analyses
The Kidney Injury Targeted Analysis Guide
FDA's Standard Safety Tables and Figures programme includes a dedicated Kidney Injury Targeted Analysis Guide for deeper evaluation of potential renal safety signals.
The guide reflects an important principle:
routine laboratory tables may identify a signal, but targeted analyses may be required to understand the signal.
What the Targeted Analysis Can Explore
Depending on the clinical-development context, analyses may examine:
- serum creatinine;
- eGFR;
- changes from baseline;
- threshold-based abnormalities;
- AKI;
- treatment differences;
- baseline kidney function;
- risk factors;
- proteinuria;
- albuminuria;
- cystatin C;
- concomitant medications;
- clinical narratives.
FDA also notes that additional information may be needed to determine whether an apparent renal signal represents true injury, an early change in kidney function, or a drug effect on creatinine handling.
Risk-Factor Subgroups
Relevant subgroups may include patients with:
- chronic kidney disease;
- older age;
- diabetes;
- cardiovascular disease;
- use of ACE inhibitors or ARBs;
- diuretic use;
- other risk factors for AKI.
Subgroup analysis can help determine whether the signal is concentrated in a population with particular susceptibility.
Narrative Review
Laboratory data alone may not explain a renal signal.
Narratives can provide information about:
- dehydration;
- hypotension;
- infection;
- sepsis;
- concomitant medications;
- hospitalization;
- timing;
- renal recovery;
- clinical diagnosis.
This is why medical review remains essential even when large-scale automated analyses are available.
Post-Marketing Pharmacovigilance
Sources of Renal Safety Information
Potential drug-induced kidney injury may be identified through:
- spontaneous adverse-event reports;
- serious adverse-event reports;
- literature;
- clinical studies;
- registries;
- patient-support programmes;
- epidemiological studies;
- regulatory databases;
- post-authorisation studies.
Post-marketing cases often contain less complete laboratory information than clinical-trial cases.
The absence of creatinine or urine data therefore does not necessarily mean that a renal adverse event did not occur.
It means that the available evidence may be insufficient to characterize the renal phenotype fully.
Case-Level Medical Review
A safety physician should distinguish between:
- a case with documented AKI and a plausible drug relationship;
- a case with creatinine elevation but insufficient clinical information;
- a case with a renal diagnosis but no supporting laboratory data;
- a case with a strong alternative explanation;
- a case with multiple potentially nephrotoxic exposures.
This avoids over-attribution.
Aggregate Safety Assessment
At the aggregate level, the safety team may examine:
- AKI reports;
- renal failure;
- nephritis;
- proteinuria;
- nephrotic syndrome;
- haematuria;
- electrolyte disturbances;
- dialysis;
- kidney transplantation;
- recurrent renal injury.
The analysis should consider reporting patterns, exposure, background disease and concomitant medicines.
Worked Examples
Example 1: Creatinine Increase With No Other Evidence of Injury
A subject has:
Baseline creatinine = 0.9 mg/dL
After treatment:
Creatinine = 1.2 mg/dL
The subject is clinically well.
There is no proteinuria.
Urinalysis is unchanged.
There is no evidence of dehydration or hypotension.
A drug-specific assessment suggests inhibition of creatinine tubular secretion.
This case warrants evaluation but should not automatically be labelled structural nephrotoxicity.
The most appropriate conclusion may be a treatment-related functional effect on creatinine handling, depending on the complete evidence.
Example 2: Acute Kidney Injury With Volume Depletion
A subject develops:
- vomiting;
- diarrhoea;
- hypotension;
- reduced urine output;
- rising serum creatinine.
The investigational medicine was also administered during this period.
The temporal relationship alone does not establish drug causality.
The medical reviewer should evaluate whether volume depletion and hypotension provide a more plausible explanation.
If renal function improves rapidly with restoration of volume and treatment of the underlying illness, this may support a hemodynamic or pre-renal mechanism.
Example 3: Tubular Injury Pattern
A subject develops:
- rising serum creatinine;
- new urinary abnormalities;
- treatment-emergent tubular injury biomarker elevation;
- no competing nephrotoxic medicine;
- plausible latency;
- improvement after treatment discontinuation.
The combination provides stronger evidence for potential drug-related tubular injury than an isolated creatinine increase.
The biomarker result still requires interpretation in the context of the specific assay and its regulatory status.
Example 4: Proteinuria With Preserved Filtration
A subject develops substantial new albuminuria while serum creatinine remains close to baseline.
This should not be dismissed simply because eGFR has not changed substantially.
The pattern may indicate an alteration in the glomerular filtration barrier.
Further clinical assessment may be required to determine:
- baseline albuminuria;
- magnitude and persistence;
- systemic disease;
- blood pressure;
- concomitant medicines;
- urinary sediment;
- other clinical findings.
This illustrates why kidney safety cannot be reduced to serum creatinine.
Limitations of Renal Safety Assessment
Serum Creatinine Is Not a Direct Injury Biomarker
Serum creatinine is primarily a marker of kidney filtration.
It can be affected by non-renal factors and may respond relatively slowly to acute injury.
eGFR Has Limitations During Rapid Change
eGFR equations are useful for describing kidney function but have limitations when creatinine is changing rapidly.
The calculated value should therefore not be treated as an exact real-time measurement of filtration during acute kidney injury.
Biomarkers Are Not Interchangeable
Different biomarkers reflect different biological processes.
KIM-1, NGAL, cystatin C and other biomarkers should not be treated as interchangeable indicators of "kidney toxicity."
Each requires appropriate interpretation.
Background Kidney Disease Is Common
Patients entering clinical trials or post-marketing surveillance may have:
- chronic kidney disease;
- diabetes;
- hypertension;
- cardiovascular disease;
- age-related decline in kidney function.
These conditions increase background renal event rates and complicate causality assessment.
Multiple Drugs May Affect the Kidney
Patients frequently receive multiple medicines that can influence:
- renal blood flow;
- filtration;
- tubular transport;
- electrolyte balance;
- immune-mediated injury.
Attribution therefore requires careful consideration of the complete exposure history.
Practical Medical Review Framework
Step-by-Step Renal Safety Review
A structured medical review can proceed through the following sequence:
- Confirm the laboratory values.
- Confirm units and reference ranges.
- Establish baseline kidney function.
- Review the longitudinal creatinine trajectory.
- Assess eGFR where appropriate.
- Assess urine output.
- Review urinalysis.
- Assess proteinuria and albuminuria.
- Review relevant renal biomarkers.
- Determine the likely renal phenotype.
- Review treatment timing and dose.
- Review concomitant medicines.
- Assess hydration and hemodynamic status.
- Review relevant medical history.
- Evaluate infection, obstruction and systemic illness.
- Consider imaging where appropriate.
- Assess dechallenge.
- Assess rechallenge if it occurred.
- Determine the most plausible mechanism.
- Assess causality.
- Assess seriousness and outcome.
- Document the medical rationale.
Medical Documentation
A medically useful renal safety assessment should make the reasoning reconstructable.
Documentation should address, where relevant:
- baseline renal function;
- creatinine trajectory;
- eGFR;
- urine output;
- urinalysis;
- proteinuria;
- albuminuria;
- biomarkers;
- renal phenotype;
- treatment exposure;
- latency;
- concomitant medicines;
- risk factors;
- competing causes;
- dechallenge;
- rechallenge;
- clinical outcome;
- causality;
- seriousness.
The objective is not simply to document that "creatinine increased."
The objective is to explain what the increase means.
Pharmacovigilance and Inspection Considerations
Inspection Perspective
During an inspection, an organisation should be able to demonstrate that important renal safety signals were identified, evaluated and followed appropriately.
Evidence may include:
- laboratory surveillance;
- targeted analyses;
- case-level medical review;
- signal evaluations;
- aggregate reports;
- medical assessments;
- relevant risk-management activities.
An inspector may reasonably ask how the organisation distinguishes:
- renal failure from isolated creatinine elevation;
- structural injury from functional effects;
- drug-related injury from competing causes;
- treatment-emergent abnormalities from baseline disease.
Common Documentation Weaknesses
Potential weaknesses include:
- no documented baseline kidney function;
- failure to distinguish AKI from chronic kidney disease;
- unexplained attribution of creatinine elevation to the drug;
- failure to review concomitant nephrotoxic medicines;
- failure to evaluate dehydration or hypotension;
- failure to assess proteinuria or albuminuria when relevant;
- overinterpretation of an exploratory biomarker;
- failure to consider creatinine transporter effects;
- inconsistent renal case classification;
- inadequate documentation of recovery.
Good documentation should allow an independent reviewer to reconstruct how the medical conclusion was reached.
Common Mistakes in Renal Safety Assessment
Common errors include:
- treating every creatinine increase as nephrotoxicity;
- treating eGFR as a direct measure of structural kidney injury;
- ignoring baseline kidney disease;
- ignoring urine output;
- ignoring proteinuria or albuminuria;
- failing to review concomitant medicines;
- failing to consider dehydration and hypotension;
- assuming a biomarker elevation proves drug causality;
- treating exploratory biomarkers as universally validated clinical tests;
- ignoring transporter-mediated creatinine increases;
- failing to distinguish tubular from glomerular injury;
- ignoring obstruction;
- relying on a single laboratory value;
- failing to examine the longitudinal trajectory;
- confusing AKI with chronic kidney disease;
- failing to document competing causes.
What an Experienced Safety Physician Looks For
An experienced safety physician does not start with:
"Did creatinine increase?"
The first question is:
"What changed in kidney function or kidney structure, and what is the most plausible mechanism?"
The reviewer then asks:
- What was the baseline kidney function?
- Is the change acute or chronic?
- Is there reduced urine output?
- Is there proteinuria or albuminuria?
- Is there evidence of tubular injury?
- Is there evidence of glomerular injury?
- Could the change be hemodynamic?
- Could the drug be affecting creatinine secretion?
- Is there dehydration?
- Is there hypotension?
- Are there other nephrotoxic medicines?
- Is there infection or systemic illness?
- Is there obstruction?
- Did the patient recover after withdrawal?
- Is there a consistent pattern across other patients?
- Is the finding biologically plausible for the drug?
Only after these questions have been addressed should the reviewer decide whether the event represents a convincing potential drug-induced kidney injury signal.
The key principle is the same one that applies across organ systems:
A laboratory abnormality is a signal requiring interpretation, not automatically a diagnosis of drug-induced organ injury.
Kidney Safety Compared With Liver Safety
Hy's Law provides a useful conceptual comparison.
In liver safety, a relatively recognizable combination of aminotransferase elevation and bilirubin elevation can identify a population-level signal of concern.
Renal safety is more heterogeneous.
There is no single renal laboratory pattern that captures all clinically important drug-induced kidney injury.
Instead, renal assessment may require integration of:
- filtration;
- urine output;
- urinary protein;
- albumin;
- tubular injury markers;
- clinical phenotype;
- renal imaging;
- exposure;
- competing causes.
This difference should be preserved rather than forcing renal safety into the framework of Hy's Law.
The appropriate lesson from Hy's Law is not that every organ should have an equivalent rule.
The lesson is that organ-specific safety assessment works best when biological injury, functional consequence, clinical phenotype and drug causality are evaluated together.
Key Takeaways
Drug-induced kidney injury is an important component of clinical development and pharmacovigilance.
The most important principle is that kidney function and kidney injury are not synonymous.
Serum creatinine and eGFR provide important information about kidney function, but they do not directly measure structural renal injury.
Renal safety assessment may therefore require consideration of:
- serum creatinine;
- eGFR;
- cystatin C;
- urine output;
- proteinuria;
- albuminuria;
- urinalysis;
- renal injury biomarkers;
- clinical findings;
- imaging;
- concomitant medicines;
- baseline kidney disease;
- hydration and hemodynamic status.
Renal injury can occur through multiple mechanisms, including tubular toxicity, glomerular injury, interstitial nephritis, vascular injury, crystal deposition, obstruction and hemodynamic effects.
FDA has supported exploratory use of several urinary biomarkers, including KIM-1, NGAL, clusterin, cystatin C, osteopontin and alpha-GST, for monitoring drug-induced renal tubular injury in early clinical development [3][4] These biomarkers should be interpreted in conjunction with conventional measures and their specific regulatory context. [3]
A particularly important issue is pseudo-nephrotoxicity, in which a drug changes serum creatinine through effects on renal handling without causing structural kidney injury.
FDA's Kidney Injury Targeted Analysis Guide provides a framework for deeper clinical-trial evaluation of potential renal safety signals, including analysis of creatinine, eGFR, proteinuria, albuminuria, cystatin C and relevant clinical factors. [1]
There is no single renal equivalent of Hy's Law.
Instead, the strongest renal safety assessment integrates function, injury, phenotype, mechanism, exposure and competing causes.
The central principle is:
Renal safety assessment should explain what changed in the kidney, why it changed, and whether the medicinal product is the most plausible cause.
References
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U.S. Food and Drug Administration. Standard Safety Tables and Figures: Kidney Injury Targeted Analysis Guide. Center for Drug Evaluation and Research.
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U.S. Food and Drug Administration. Standard Safety Tables and Figures (ST&Fs). Center for Drug Evaluation and Research.
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U.S. Food and Drug Administration. Letter of Support for Drug-Induced (DIKI) Renal Tubular Injury Biomarker(s). November 23, 2016.
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U.S. Food and Drug Administration. Reviews: Qualification of Biomarker: clusterin (CLU), Cystatin-C (CysC), Kidney Injury Molecule-1 (KIM-1), N-acetyl-beta-D-glucosaminidase (NAG), Neutrophil Gelatinase-Associated Lipocalin (NGAL), and osteopontin (OPN).
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Kidney Disease: Improving Global Outcomes (KDIGO). KDIGO 2012 Clinical Practice Guideline for Acute Kidney Injury.
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Kidney Disease: Improving Global Outcomes (KDIGO). KDIGO 2026 Clinical Practice Guideline for Acute Kidney Injury (AKI) and Acute Kidney Disease (AKD): Public Review Draft. 2026.
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Kidney Disease: Improving Global Outcomes (KDIGO). KDIGO Clinical Practice Guideline for the Evaluation and Management of Chronic Kidney Disease.
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U.S. Food and Drug Administration. Drug-Induced Renal Injury List (DIRIL) Dataset. Center for Drug Evaluation and Research.