Manuel B. Garcia

Manuel B. Garcia serves as the Senior Director for Educational Technology and Digital Learning at FEU Institute of Technology, Manila, Philippines. Read More

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Do Pilot and Feasibility Studies Need Ethics Approval?

Pilot and feasibility studies involving human participants may require ethics approval just like larger studies. Their preliminary purpose or small sample size does not postpone ethics requirements until the main study.

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Pilot Studies and Ethics Approval Guide 38 of 398
01 · The Question

If It Is Only a Pilot, Do You Need Ethics Approval Yet?

You are not conducting the “real” study yet. You only want to test whether recruitment works, whether participants understand the questionnaire, whether an intervention can be delivered, whether equipment functions as expected, or whether the full study is practical.

Because the sample is small and the findings are preliminary, it can be tempting to treat the pilot as preparation rather than research. But from a participant's perspective, being one of the first ten people exposed to a research procedure is still participation.

02 · The Short Answer

Pilot Status Does Not Automatically Exempt a Study

In Brief

A pilot or feasibility study involving human participants may require ethics approval, exemption determination, or another applicable ethics pathway before it begins; being preliminary, small, or conducted before a larger study does not itself create an exemption.

The relevant question is what participants will actually experience and what information or materials researchers will obtain. Some low-risk pilot activities may qualify for exemption, while others may require expedited or full review according to the governing framework.

03 · What You Need to Know

A Pilot Study Is Still a Study

What Is a Pilot Study?

A pilot study is a smaller-scale investigation conducted before, or sometimes as an initial phase of, a larger study. Its purpose is usually to test aspects of how the future research will work rather than to provide a definitive answer to the main substantive research question.

A pilot might examine recruitment rates, questionnaire comprehension, intervention delivery, adherence, data-collection procedures, measurement variability, retention, technical processes, or other practical features of the planned study.

The term is sometimes used loosely, so researchers should state exactly what the pilot is intended to learn rather than relying on the label.

What Is a Feasibility Study?

A feasibility study asks whether and how a proposed study, intervention, or procedure can be carried out successfully in a particular context.

Pilot and feasibility studies overlap substantially, and terminology varies across disciplines. A pilot study is often understood as one form of feasibility work conducted on a smaller scale, while feasibility research can address a broader set of questions about whether a future study is practical.

For ethics purposes, the terminology is less important than the activities participants undergo.

Small Sample Size Does Not Create an Ethics Exemption

One of the most persistent misconceptions is that a study becomes too small to require ethics review.

Research-ethics requirements generally do not begin at participant number 20, 50, or 100. If the first five participants undergo a research intervention, provide sensitive information, or allow identifiable private data to be collected, the relevant ethical issues exist for those five people.

A small sample can reduce the number of people exposed to risk. It does not make each participant's rights or welfare less important.

“Preliminary” Describes the Research Stage, Not the Ethics Status

A pilot may produce preliminary evidence. That does not mean participant protections are preliminary too.

The study can still involve informed consent, recruitment, interventions, privacy, confidentiality, compensation, adverse events, vulnerable participants, biological specimens, or identifiable data. Those issues should be assessed before the pilot begins when the applicable framework requires prospective review.

Preliminary research Describes where the study sits in the broader research program and the tentative purpose of its findings.
Exempt research Describes a formal ethics status reached when the study satisfies defined exemption criteria under the applicable framework.

A Pilot Can Expose Participants to the Same Intervention as the Main Study

Some pilot studies test the exact intervention intended for the later trial. Participants may receive a behavioral intervention, use a device, undergo repeated assessments, provide specimens, take medication, or experience another research procedure.

The fact that researchers are primarily measuring feasibility rather than effectiveness does not remove those exposures.

Indeed, early studies can sometimes contain additional uncertainty because investigators are still learning whether procedures are practical, tolerable, or safe enough to implement as intended.

A Questionnaire Pilot Can Still Involve Human Participants

Not every pilot is clinically intensive. Researchers frequently pilot questionnaires or interview guides with a small number of people to determine whether questions are understandable.

If individuals merely help researchers proofread wording in a way that does not constitute research under the applicable framework, the ethics analysis may differ. If researchers systematically collect participants' responses, experiences, or identifiable information as part of a research investigation, however, the activity may fall within human-participant research requirements.

The distinction depends on what the activity is designed to accomplish and what information is being obtained.

Testing Recruitment Can Itself Involve Research Participants

A feasibility study may ask whether researchers can recruit a particular population. That sounds administrative, but actually testing recruitment can involve approaching real people, screening them, collecting eligibility information, and perhaps enrolling them into research procedures.

Once potential participants are contacted for a research study, recruitment and screening raise ethical issues concerning privacy, voluntariness, appropriate information, eligibility data, and sometimes sensitive characteristics.

Researchers should not assume that “we're only testing recruitment” means recruitment can begin before the applicable ethics process is complete.

Testing Consent Procedures Can Require Prior Ethics Review

A pilot may also examine whether potential participants understand a consent form or whether a recruitment script communicates information effectively.

If researchers systematically collect information from individuals to evaluate the consent process as part of human-participant research, the pilot itself may require an ethics determination.

There is an obvious circularity otherwise: researchers cannot simply use unreviewed participants to test whether the consent process for a future reviewed study works.

Method Development Is Not Automatically Human-Participant Research

There is an important boundary. Researchers can conduct preparatory work without necessarily involving human participants.

Programming a survey, testing database logic with synthetic records, rehearsing interview procedures among research-team members, calibrating equipment without collecting research information about people, or simulating recruitment workflows may not constitute human-participant research.

Once real participants, identifiable private information, or human biological materials enter the activity, reassess whether the applicable research-ethics framework is engaged.

Using Real Records to “Test the Analysis” Can Also Trigger Ethics Questions

A researcher may want to test statistical code or data-cleaning procedures before the main study by opening a small subset of real patient, student, or employee records.

The fact that the researcher calls this a technical pilot does not determine its ethics status. If identifiable private information is being obtained or analyzed for research, the same questions concerning secondary use of existing data can arise.

Where possible, synthetic or appropriately nonidentifiable data may allow some technical procedures to be tested without involving real participants' information.

A Pilot Can Qualify for Exemption

Saying that pilots may require ethics oversight does not mean every pilot requires full committee review.

A low-risk pilot involving an anonymous adult survey, ordinary educational activity, benign behavioral procedure, or another eligible method may satisfy an exemption category under the applicable framework. Other pilots may qualify for expedited review.

The review pathway follows the actual protocol, not the word pilot.

Approval for the Pilot Does Not Automatically Approve the Main Study

A pilot and the later definitive study may differ in sample size, sites, interventions, eligibility criteria, measures, duration, or analytic objectives. Ethics approval for one should not be treated as blanket approval for the other unless the ethics body has specifically reviewed the protocol structure that includes both phases.

If the main study was included prospectively in the approved protocol with clear criteria governing progression from pilot to main phase, institutional procedures may permit the project to continue accordingly. Otherwise, an amendment or new submission may be necessary.

Changes After the Pilot Should Be Reflected in the Ethics Documentation

The entire point of piloting is to learn what needs changing. A questionnaire may be rewritten, eligibility criteria adjusted, recruitment expanded, intervention duration changed, or new measures added.

Those modifications can affect participant information, risk, consent, data collection, or review classification. Follow the applicable amendment process before implementing material changes in the main study.

Data From the Pilot May or May Not Belong in the Main Analysis

Researchers sometimes want to include pilot participants in the final dataset. Whether that is methodologically defensible depends on the design and whether procedures changed between phases.

Ethically, the approved consent and protocol should also be considered. Participants should not be told their information is being collected only to test procedures if investigators actually intend to combine their data with the definitive study in ways not covered by the approved plan.

Plan this possibility prospectively when feasible.

A Pilot Is Not a Loophole for Starting the Main Study Early

Calling the first few participants a “pilot sample” does not authorize researchers to begin an otherwise reviewable study while the full protocol is still awaiting ethics approval.

If those individuals undergo the same research procedures contemplated in the pending protocol, they are participants in research regardless of the informal label placed on their enrollment.

Watch Out

Do not recruit the first few participants “just to test things” while ethics approval for the study is still pending. If the pilot itself involves covered human-participant research, obtain the required approval or determination before recruitment and data collection begin.

Pilot Studies Should Have Their Own Scientific Justification

Ethical research should have sufficient value to justify participant involvement. A pilot therefore needs a clear question of its own: what uncertainty about feasibility, procedures, recruitment, measurement, intervention delivery, or study operations is it intended to resolve?

A vague plan to “try the study on a few people and see what happens” provides a weak basis for exposing participants to burden or risk.

Ethics review can appropriately ask whether the pilot is designed well enough to answer the feasibility question that supposedly justifies involving participants.

Do Not Use Pilot Status to Excuse Weak Consent or Data Protection

Preliminary research still generates real records. Audio recordings, questionnaire responses, clinical measurements, biological specimens, contact information, and screening data require appropriate handling from the first participant onward.

Consent documents and privacy protections should accurately describe what the pilot involves, what will happen to participants' information, whether data may be retained for the later study, and what happens if the main study never proceeds.

04 · A Practical Example

A Ten-Person Pilot Is Still Human-Participant Research

Hypothetical Example

Piloting a Digital Stress-Management Intervention

A research team plans a larger trial of a four-week digital stress-management program for university students. Before committing to the full study, the team wants ten students to complete the intervention so researchers can assess recruitment, adherence, questionnaire completion, and technical problems.

Purpose The primary aim is feasibility rather than definitive evidence of effectiveness.
Participant experience Real students are recruited, consented, enrolled in the intervention, and asked to provide repeated information about stress and well-being.
Ethics implications The study involves recruitment, personal information, an intervention, repeated assessments, confidentiality, and possible participant distress even though only ten people are enrolled.
Before the pilot The team obtains the ethics determination required for the pilot protocol rather than waiting for the larger trial.
After the pilot The researchers revise the intervention and questionnaires based on what they learned and submit any required amendment or main-study protocol before implementing those changes with additional participants.

The pilot's small scale changes what the researchers hope to learn. It does not make the ten participants provisional human beings until the sample size becomes respectable.

05 · What Researchers Often Get Wrong

Common Misunderstandings About Pilot and Feasibility Studies

Misconception

“It's Only a Pilot, So Ethics Approval Comes Later”

If the pilot itself constitutes covered human-participant research, the relevant ethics requirements apply before the pilot begins. The later main study does not provide retrospective protection for pilot participants.

Misconception

“Ten Participants Are Too Few to Need Ethics Review”

There is no universal minimum sample size below which human-participant research ceases to raise ethical obligations. Risk and participant protections exist from the first participant.

Misconception

“We're Testing the Questionnaire, Not Studying the Participants”

Sometimes questionnaire development is merely preparatory work. But if researchers systematically collect information from real people as part of research to evaluate the instrument, the activity may itself involve human participants. Assess what is actually being collected and why.

Misconception

“Pilot Approval Automatically Covers the Main Study”

Not necessarily. The main study may differ materially from the pilot. Follow the ethics body's requirements for amendments, progression between phases, or a separate main-study submission.

Misconception

“Pilot Data Can Always Be Added to the Final Dataset”

Methodological changes between phases can make pooling inappropriate, and the approved protocol and consent arrangements may also affect whether pilot data can be used in the definitive analysis. Plan the intended use prospectively.

06 · What This Means for You

Classify the Pilot by What Participants Actually Experience

Do not ask whether pilots as a category need approval. Describe the activity that will occur before the main study and assess that activity under the applicable ethics framework.

A simple decision framework

If the pilot uses only synthetic data, simulations, or internal technical testing without human-participant research
Check institutional requirements, but formal human-research ethics review may not be engaged.
If real people will be recruited or provide research information
Assess the pilot as human-participant research before recruitment begins.
If the pilot involves identifiable existing records
Assess the secondary-data research requirements rather than treating the work as purely technical testing.
If the pilot appears low risk
Check whether it qualifies for a defined exemption or another appropriate review pathway.
If pilot findings lead to changes in the main study
Follow the applicable amendment or submission procedure before implementing material changes with additional participants.

The practical sequence is simple: pilot, learn, revise, then proceed through the appropriate ethics process for whatever the study has become. Ethics review should be built into that sequence rather than added somewhere between “revise” and “submit the paper.”

07 · A Quick Checklist

Before Starting a Pilot or Feasibility Study

Before the first pilot participant, check:
State the specific feasibility or pilot question the study is intended to answer.
Determine whether real people, identifiable private information, or human biological materials will be involved.
Assess participant risks and burdens rather than assuming a small sample makes them negligible.
Determine whether recruitment, screening, consent testing, or questionnaire piloting itself constitutes human-participant research.
Check whether the pilot qualifies for exemption or another appropriate review pathway under the governing framework.
Clarify whether pilot participants or their data may continue into the main study and reflect that accurately in the protocol and consent process.
Obtain the required ethics determination before recruitment or research data collection begins.
Submit required amendments or a main-study protocol when pilot findings lead to material changes.
08 · Frequently Asked Questions

Frequently Asked Questions About Pilot Study Ethics

Does a small pilot study need ethics approval?

It can. Small sample size does not itself create an exemption. If the pilot involves human-participant research, determine the appropriate ethics pathway before it begins.

Do I need ethics approval just to pilot a questionnaire?

It depends on what the pilot involves. Internal technical testing or informal proofreading can differ from systematically collecting information from real participants to evaluate an instrument as part of research. Follow your institution's determination process when the status is uncertain.

Can I recruit a few pilot participants while the main ethics application is pending?

Not merely because you call them pilot participants. If their participation constitutes covered research requiring prior approval, obtain the required determination before recruitment and data collection begin.

Can a pilot study be exempt from ethics review?

Potentially. A pilot can satisfy an applicable exemption category just as another study can. Eligibility depends on the actual procedures, participants, information collected, risks, and governing framework rather than pilot status.

Does ethics approval for my pilot cover the full study?

Only if the approved protocol and institutional process explicitly cover progression into the main study under the relevant conditions. Otherwise, an amendment or separate approval may be required.

Can pilot participants be included in the main study?

Sometimes, but this should be considered prospectively. Methodological changes can affect whether pooling is scientifically appropriate, while the approved protocol and consent process should cover the intended use of participants' data.

Is a feasibility study different from a pilot study for ethics purposes?

The terminology can differ across disciplines, but ethics review generally focuses on what participants undergo and what researchers collect rather than the label. Either type of study may require an ethics determination when human participants are involved.

09 · The Bottom Line

Participant Protections Begin With the Pilot

The Bottom Line

Pilot and feasibility studies involving human participants can require ethics approval or another formal ethics determination before they begin; small sample size and preliminary aims do not postpone ethics requirements until the main study.

Assess the pilot according to what real participants will experience and what information or materials researchers will obtain. Then use what the pilot teaches you to revise the main study through the appropriate amendment or review process before exposing additional participants to the revised protocol.

10 · Sources and Further Reading

Authoritative Sources on Pilot, Feasibility, and Human-Participant Research

11 · Cite this Guide

How to Cite This Guide

This guide is intended to be read, shared, and used in research, teaching, and academic work. If you draw on its ideas, explanations, or other content, please acknowledge the source by citing the guide. Doing so gives appropriate credit and helps your readers locate the original resource.

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