TY - JOUR T1 - From Quality-by-Design to Quality-by-Intelligence: Governance of AI-Assisted Pharmaceutical Manufacturing Systems AU - Michael Turner AU - Sophia Nguyen AU - David Clark AU - Emma Wilson JF - EAMD 3 Y1 - 0 VL - 0 IS - 0 SP - 161 N2 - Artificial intelligence is rapidly entering pharmaceutical manufacturing through predictive analytics, process analytical technology, continuous manufacturing platforms, and data-driven quality control. These developments promise earlier detection of process deviation, adaptive optimization of critical process parameters, and more responsive assurance of critical quality attributes. Yet the dominant regulatory and quality vocabulary remains anchored in Quality-by-Design, a paradigm built around pre-defined knowledge, structured risk assessment, and validated control strategies. The central problem is that AI-assisted manufacturing systems do not behave like conventional pharmaceutical processes governed solely through fixed design spaces. Machine learning models may change performance as data distributions shift, as sensors age, as materials vary, or as feedback loops alter the operating environment. This creates a governance gap between the static logic of pre-validation and the dynamic reality of algorithmic decision-making. This critical conceptual review examines whether Quality-by-Design remains sufficient for AI-assisted pharmaceutical manufacturing. It argues that QbD is still necessary but no longer sufficient because it was designed for processes whose boundaries, models, and control logic can be defined before routine operation. AI-assisted systems require an additional governance logic capable of supervising data, models, explanations, adaptation, and accountability throughout the product lifecycle. The review develops the concept of Quality-by-Intelligence as a forward-looking governance framework. QbI does not discard QbD; rather, it extends it by embedding data stewardship, model lifecycle management, explainable decision-making, adaptive risk control, and regulatory translation into the pharmaceutical quality system. Its purpose is to govern not only the manufacturing process, but also the intelligence layer that increasingly mediates quality decisions. Quality-by-Intelligence reframes pharmaceutical quality as an adaptive, evidence-generating, and accountable system rather than a one-time design achievement. The transition will require new regulatory expectations, new validation evidence, new operator competencies, and stronger collaboration between industry, regulators, and academic experts. Without this shift, AI may be deployed into manufacturing faster than the quality systems needed to govern it. UR - https://pubsys.eshragh.co/v509528480 ER -