Education · Trial master fileUpdated October 16, 2026

eTMF vs a shared drive: when a folder is enough, and when it is not

Many small and academic teams keep their trial master file on a shared drive. Sometimes that is a defensible choice, sometimes it is the first thing an auditor questions. This page compares the two on the controls that matter, gives a decision rule, and says plainly that Capture is an EDC, not an eTMF.

  • Control-by-control comparison
  • Decision rule by trial risk
  • Capture is not an eTMF

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Where each option stands (typical, not vendor-specific)
Plain shared driveConfigured shared driveDedicated eTMF
Folder structure from an index
Version history
Restricted, reviewed access
Audit trail of who filed or changed what
Completeness and timeliness reports
Qualified e-signature and review workflow
Illustrative. Configuration and validation decide the real answer.

The short answer

  • A shared drive is a place to put files. An eTMF is a place to prove how the files got there. The difference is evidence: who filed a document, when, which version superseded which, who could see it, and whether anything went missing.
  • Regulators do not ask for a product; they ask for a file that works. ICH GCP expects the sponsor and the investigator to know where their essential documents are, and the storage to support identification, version history, search and retrieval. A drive can meet some of that. The question is how much you can show.
  • Risk decides. A small investigator-led study with a few sites and a low-risk product can often defend a well-configured drive. A multi-country regulatory trial usually cannot, because the volume and the number of hands make unaided control fail.
  • The cheap version of "shared drive" fails first. Open folders, files named by hand and no review of who has access are the findings, not the drive itself.
  • Capture is not an eTMF. It is the EDC, eConsent, ePRO and randomization side, and it exports several records that belong in either kind of file. It does not store your regulatory binder.

The two options

What you are actually comparing

The trial master file is the sponsor's set of essential documents: the records that, individually and together, let someone reconstruct how the trial was run and whether the data can be trusted. An eTMF is software built to hold that set electronically, with a structure based on a reference model, metadata for each document, controlled access, an audit trail and tools to check that the file is complete and current. A shared drive (a network folder, SharePoint, Google Drive or similar) is general file storage that you configure to behave like a TMF.

The comparison matters because the content is identical. The protocol, approvals, contracts, delegation logs, training records and monitoring reports are the same whether they sit in a purpose-built system or in a folder tree. What differs is how much of the control work the system does for you and how much is done by people and SOPs. For the difference between the TMF and the data system, see EDC vs eTMF. To build the file itself, see how to set up a trial master file. This page is about where to keep it.

The investigator site file is a separate question

Each site keeps its own investigator site file. Many sites run on paper binders or the hospital's own folders, and the sponsor does not choose that. The decision here is about the sponsor-side master file. For the site set, see the investigator site file index template.

The wording in the guideline

ICH E6(R2) section 8 asks that sponsor and investigator keep a record of where their essential documents are stored, and that the storage system supports identification, version history, search and retrieval. It also allows the list of documents to be supplemented or reduced in advance, based on how important and relevant each is to the trial. ICH E6(R3), adopted in January 2025, uses "essential records" and an essentiality test, and says its table is not a rigid checklist. Check the current text that your regulator and sponsor apply; this page paraphrases and is not legal advice.

Control by control

What a shared drive can and cannot evidence

Read the middle column as "what you must add to the drive" rather than "what it can never do". Every item can be addressed with configuration and procedure; the cost is the effort and the proof.

Control an inspector looks forOn a shared driveIn a dedicated eTMF
Document index and structureFolder tree copied from a model or your own index. Easy to start; drifts when people add folders.Index built in, usually from a reference model, with an expected-documents list per country and site.
Naming, version and metadataFile names carry the rules, and only if everyone follows them. Version history exists in many drives but is not tied to document status.Metadata fields (type, version, date, country, site) captured at upload; superseded versions tracked.
Access controlFolder permissions you set and must review. Link sharing and inherited permissions are common gaps.Role-based access, restricted areas for unblinded material, and user lists reportable for review.
Audit trailDepends on the product and the licence. Often a log of file events, not a trail of what changed and why.Filing, change and deletion history kept as part of the system.
Review and approval of filed documentsDone by email or a separate form, then filed. The link between review and file is manual.Workflow for quality check and approval, recorded in the system.
SignaturesWet-ink scans or a separate signing tool. Evidence sits outside the drive.Often built in; whether it meets your signature requirements depends on validation.
Completeness and timelinessA spreadsheet tracker someone maintains by hand.Reports on expected versus filed documents and time to file.
Deletion and recoveryUsers can delete or overwrite; recycle bins are time-limited.Controlled deletion, retained history, designed for retention rules.
Validation and change controlVendor builds it for general use. Your evidence that it is fit for GCP records is yours to produce.Vendors often supply validation packs; you still own the fitness decision.
Inspector accessScreen share or read-only account you create for the day.Read-only inspector roles and export tools.

This table describes typical behaviour of the two categories and says nothing about any specific product. Check any product against its own documentation and your own validation.

Decision rule

How to decide: five questions that move the answer

Rather than argue the two options in the abstract, answer five questions about your trial. The more answers fall to the right, the harder it is to defend a drive.

1. How many sites, countries and contributors?

A single-site or two-site study with three people filing is controllable by habit. Ten sites across several countries, with a CRO and several vendors filing, is not. Volume is what turns "we follow the naming rule" into "we cannot prove it".

2. Is the file feeding a marketing application?

If the data will support a regulatory submission, expect the file to be examined by inspectors who see many TMFs. A file that looks improvised invites a deeper look. For an investigator-led study with publication as the aim, the bar is different, though GCP still applies.

3. Who must be kept out of which documents?

Randomization lists and unblinding records need tight access. Folder permissions can do this, and so can an eTMF, but the review of who has access has to be a recurring task, not a start-up setting. See blinded and unblinded role management for the data-side equivalent.

4. Can you show filing was timely?

Inspectors often look at whether documents were filed when generated, not assembled before the visit. A drive with file-modified dates is weak evidence, because dates change when files are moved or re-saved. If your drive cannot give you a trustworthy filing date, you need another record of it.

5. What will you spend, and who will do the checking?

A drive costs little to start and a lot of someone's time to keep controlled. An eTMF costs more to buy and configure, and removes part of that time. The honest comparison is licence plus validation against the hours of a TMF owner over the life of the trial.

TMF risk signals · demo trial

Sites filing

3

Contributors

5

Overdue filings

7

Open access reviews

2

Start-up documents filed38/42

4 outstanding

Filed within target time24/40

Hand-tracked

Users with a review date3/8

Folder permissions

Demo numbers. If you cannot produce rows like these, that is the gap.

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If you choose a shared drive

Seven steps to make a shared drive defensible

None of this makes a drive an eTMF. It makes the choice documented, controlled and explainable.

  1. 1

    Write a TMF plan that names the drive

    State the system, the index it follows, the owner, who may file, and why a drive is proportionate to this trial's risk. A reasoned decision on file is better than an unexplained one.

  2. 2

    Lock the structure

    Create folders once from your index and remove the right to add top-level folders. Record the index version.

  3. 3

    Fix naming and metadata

    One rule for type, version, date and site code. Keep a register (a controlled spreadsheet) with the filing date you can defend, since file dates are not reliable.

  4. 4

    Restrict and review access

    Give people the least access they need, switch off open link sharing, hold randomization and unblinding material in a separate restricted area, and review the user list on a schedule with a signed record.

  5. 5

    Turn on every log the drive offers

    Keep file activity logs, version history and deletion protection, and export the logs to a controlled location at agreed intervals.

  6. 6

    Track completeness and timeliness by hand

    Maintain an expected-documents tracker per site and run a monthly quality check, recording findings and closure. This is the work an eTMF automates.

  7. 7

    Plan the exit

    Decide how you will export the file with its metadata at close-out, how you will archive it, and how you would migrate if the trial grows. See data archiving and retention.

Worked scenarios

Three illustrative trials and where each lands

These are invented examples for reasoning, not recommendations for your trial.

ScenarioFeaturesLikely fit
Investigator-led pilot, one site, 40 participants, approved product used in labelThree staff file; no regulatory submission planned; sponsor is the hospitalA configured, access-reviewed drive with a TMF plan and a hand tracker is usually proportionate. Agree it with your sponsor and QA.
Phase 2, five sites in two countries, CRO involved, open-labelEight contributors; submission to regulators possible laterBorderline. A drive needs heavy procedure. Price an eTMF, or ask whether the CRO provides one as part of the contract.
Phase 3, twelve sites, four countries, blinded, regulatory submissionMany contributors and vendors; restricted unblinding records; inspection likelyA dedicated eTMF is the safer default. The volume and the evidence expectations outgrow hand control.

Phase and size are signals, not rules. The risk to participants and to data reliability is what decides how much control you need.

Where Capture fits

Capture is the data system that feeds either kind of file

Capture is an all-in-one clinical trial platform: EDC, eCRF builder, ePRO, eConsent and randomization with one audit trail. It is not an eTMF and it does not store your regulatory binder, contracts or delegation logs. What it does is produce records that belong in the master file, whichever way you keep it, so they come from a system with its own controls instead of being rebuilt by hand.

  • Blank eCRF PDF: cover page, form index, visit-by-form matrix and every approved form printed empty.
  • Signed consent exported as PDF with embedded signature data, timestamps and audit trail.
  • Field-level audit trail export: user, timestamp, old value, new value and reason for change.
  • CSV or Excel export with a data dictionary, and SDTM datasets as SAS XPT with Define-XML.
  • Role-based access, so data-side access is separate from your document-side permissions.
Audit trail software for clinical trials
Records to file from the data system · demo
TMF-INDEX-DEMO-v1.0.xlsx1/4 complete
  1. 5.2

    Blank eCRF PDF, approved form versions

    From platform export

    Complete
  2. 5.4

    User list and access review

    Draft
  3. 5.5

    Audit trail export at database lock

    To do
  4. 7.3

    Signed consent examples (redacted)

    To do
Demo index. Your TMF plan sets the numbering.

How to evaluate

Questions to ask before you pay for an eTMF

Use these with any vendor. They avoid feature lists and test the evidence you will need.

Reference model and index

Which structure is built in, and can you adapt it for a smaller trial without losing the audit trail?

Audit trail

Does it record filing, change and deletion with user and time, and can you export it?

Access model

Can you create restricted areas, and report who has access on a given date?

Validation support

What evidence does the vendor provide, and what must you do yourself?

Completeness reporting

Can you see expected versus filed documents by site and by time to file?

Exit and archive

Can you export the whole file with metadata at close-out, in a readable format, without extra fees?

Total cost

Licence, set-up, validation, training and per-study charges, against the hours of a TMF owner.

CRO or sponsor provision

Is an eTMF already part of your CRO contract or your institution's tools?

What goes wrong

Failure patterns on shared drives, and the fix

The recurring problems are not exotic. Documents are filed in batches before a monitoring visit, so the file shows a tidy state that was not real at the time. Superseded protocol versions sit next to current ones with no mark. A departed team member still has access. A restricted randomization file is reachable through an old shared link. A tracker spreadsheet is correct on the day it is updated and wrong a week later.

Each has the same remedy: make the rule visible, record the check, and keep the evidence. A monthly quality check that is minuted and signed does more for inspection readiness than a better folder tree. The monitoring visit report template shows how a monitor writes up such findings, and the delegation log template is the record that tells you who should have had access in the first place. For the wider move to risk-proportionate quality, read the ICH E6(R3) guide.

FAQ

Questions teams ask before they switch

Something not covered here? Ask us directly.

Is a shared drive acceptable as a trial master file?

It can be, for a small, lower-risk trial, if you configure it with a locked structure, restricted and reviewed access, version history, logs and a quality-check routine, and document why it is proportionate. There is no rule that requires a product called an eTMF, but you must be able to evidence the controls. Agree the approach with your sponsor and QA first.

Can I use SharePoint or Google Drive as an eTMF?

You can use them as the storage for a TMF, and many teams do. Whether they behave like an eTMF depends on how you configure and validate them. Plain folder sharing does not give you an audit trail of filing, completeness reporting or access reports without additional work.

What does an eTMF add that a shared drive does not?

Typically a built-in index, document metadata, an audit trail of filing and changes, controlled access, review workflows, and reports on completeness and timeliness. You can reproduce some of this on a drive by procedure, at a cost in time and with weaker evidence.

Do regulators require an eTMF?

GCP sets expectations for the content and control of the file, not the product. It asks that essential documents are identifiable, versioned, searchable and retrievable, and that they are protected and retained. Check the current text of the guidance that applies to your trial.

Is Capture an eTMF?

No. Capture is an EDC, eCRF, ePRO, eConsent and randomization platform. It does not store your regulatory documents. It exports records that belong in a trial master file, such as the blank eCRF PDF, signed consent PDFs and the audit trail.

When should a small trial move from a drive to an eTMF?

When the number of sites, countries and contributors makes hand control unreliable, when the data will support a regulatory submission, or when you cannot show timely filing and access review from your current setup. Moving mid-trial is possible but costs migration effort, so decide early.

Does my CRO provide an eTMF?

Many CROs run trials in their own eTMF. If you use one, ask in the contract what you receive at the end, in what format, and how you get access during the trial.

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