The 2022 search approach is no longer working. Companies need to think critically about how they are acquiring top regulatory, clinical and commercial executives or risk their programs in this new regulatory and market reality.
For the past two years, life sciences boards operated under a single directive: survive lean. Faced with a capital winter unlike anything the industry had seen in a generation, biopharma companies executed brutal layoff cycles. Cut the fat, protect the runway, live to fight another day.
The problem is that many organizations did not just cut fat. They cut straight through muscle. As 2026 brings a genuine thaw, capital is moving again and pipelines are reactivating, but a painful truth is surfacing. The leadership talent required to execute that growth is simply no longer there.
As the President of PPG Advisory Partners, part of Planet Pharma Group, I place senior executives across biopharma and biotech. The conversations we are having every week tell a consistent story: companies are ready to move, and the talent they need has moved on. This is not a market correction problem. It is a self-inflicted wound.
Where talent went
Top-tier regulatory, clinical and commercial executives did not disappear during the downturn. They made smart, calculated decisions to protect their careers.
The first wave moved to medtech giants and established pharma players offering something venture-backed biotechs had stopped providing: corporate stability and the expectation of still having a job in twelve months.
The second wave went fractional. They picked up three or four early-stage clients and discovered they could earn more, with far less personal risk, than they ever had as a full-time employee.
Last quarter, I spoke with four senior regulatory executives who turned down full-time VP roles. All four are now consulting across multiple portfolio companies and have no intention of giving that up without an extraordinary incentive. The pitch of “come join our exciting journey” lands differently when an executive is already on several journeys at once, completely insulated from the career risk of concentrating on just one pipeline.
A search can sink a program
Our firm was recently brought in to rescue a search that had been unraveling for four months. The client was a rare disease company fresh off a Series B raise, needing a vice president of regulatory affairs to manage their FDA strategy through a pivotal submission window. Alongside their initial search partner, they ran a 2022 playbook: a passive database search, a conservative offer, and a standard six-month severance clause.
The result was a wall. All three finalists passed on the opportunity. One had moved to a large pharma company and had no appetite for early-stage volatility. The other two refused to leave their fractional portfolios without what one described, bluntly, as “irreversible downside protection.”
What makes this particularly painful is that regulatory affairs does not operate on a forgiving timeline. Pre-NDA Type B meeting slots, IND milestones and orphan drug designation timelines are fixed points. They do not move just because your interview process is lagging. While the previous firm recycled the database, the submission calendar bled out.
We stepped in, reframed the engagement as a governance negotiation, restructured the offer mechanics, and placed a tier-one regulatory operator within forty-five days. A 2022 hiring playbook is, in the current market, functionally useless.
The hidden cost: Title inflation and the COVID hangover
Here is the part nobody wants to talk about. The danger is not just the vacant seat. It is what happens when companies try to fill it badly, and the COVID-era left a hidden liability that is only now coming due.
During the 2020 through 2022 hiring surge, the industry developed a widespread habit of over-promoting. Directors became VPs. Senior managers became directors. Titles expanded faster than actual experience could follow, and for a time, it did not matter much. The FDA was running on expedited, pandemic-era timelines, and nobody was stress-testing the depth behind the titles.
That tolerance is gone. Data from recent Prescription Drug User Fee Act (PDUFA) cycles shows that roughly 37 percent of all BLAs and NDAs receive a Complete Response Letter (CRL) on their first cycle. Once a CRL lands, the path back to approval averages over a year (and can stretch to four) depending on the severity of the deficiencies. For a pre-commercial biotech, that is not a temporary setback; it is potentially company-ending.
And that was before the FDA itself became a source of operational uncertainty. The Department of Health and Human Services’ (HHS) restructuring under the current administration eliminated roughly 3,500 agency positions, including key staff overseeing drug approvals and biologics review. I have had clients call me mid-search in genuine crisis: a reviewer reassigned with zero handoff, a CRL that came back harder than expected or an advisory committee date that moved without explanation.
The agency those COVID-era VPs learned to work with no longer operates the same way. Knowing how the agency actually functions today, who to call, and how to read the signals is institutional knowledge that has never been worth more.
Which is exactly why a title alone cannot be the proxy anymore. A resume that reads “VP, Regulatory Affairs” with three years of tenure is not the same as one belonging to someone who has steered a program through an adversarial FDA relationship or dealt with a complex manufacturing deficiency response under real pressure. The question for boards is no longer “what is this person’s title?” It is “what have they actually navigated?”
What it takes to win
The good news is that some organizations have figured out how to adjust to this reality.
First, they lead with stability, not just upside. Almost every candidate in this market is risk-averse. They want to see the data, understand the cash runway, and hear a straight answer about where the program stands. Burying those details behind a grand vision pitch is a fast way to lose top talent.
Second, they have stopped treating flexibility as a concession. A proven regulatory executive on a fractional or interim-to-perm basis often delivers more immediate value than a less experienced full-time hire. Frequently, these executives convert to permanent roles once they have seen the organization up close. Holding out for a traditional full-time structure purely out of habit is leaving elite talent on the table.
Finally, they treat leadership searches as governance decisions, not HR transactions. Compensation, equity, and severance are deal terms, full stop. Tier-one candidates are routinely negotiating six to eighteen months of salary continuation and accelerated equity vesting as baseline expectations, not aggressive asks. Fighting those terms is a quick way to lose a finalist to a competitor who understands the market.
The reckoning
The boards that cut their way through the downturn believing they were preserving capital are discovering they were simply deferring much larger costs into the future. These decisions made tactical sense at the time, but the bill is arriving now.
Capital is returning to life sciences, and that is genuinely exciting. The organizations that successfully capitalize on this recovery will be the ones that treat leadership acquisition with the exact same rigor they bring to clinical trial design. Execution requires experts, and right now, those experts are not waiting around.
