There is usually a requirement to retain study-specific records for any type of clinical study, including those that are not regulated by Good Clinical Practice requirements (and therefore, not specific TMF requirements). So the set of documents are likely to be much smaller than for an IND/CTA clinical trial and it may not be referred to a “a TMF”, but you’ll still need to retain documentary evidence of what you have done. The TMF Reference Model Project has a sub-team that is developing a reduced Reference Model for this type of study, with many of the artifacts being advisory in the absence of specific global regulatory requirements.