Open CAPA associated with critical/ major deviations need to be included in the main body of PSMF; hence companies tend to be conservative in categorizing observations.
For your question, there is no direct answer, as this depends on the following factors:
1. Extent of delay of ICSR, the type (Seriousness/ expectedness) and the significance of the event. E.g., a non serious expected ICSR Vs a Serious Unexpected ICSR or 5 days delay Vs 75 days delay
2. Reason for delay in PSUR submission - Technical/ portal Issues? QPPV availability? Delay in review or sign off?
3. Repetitive observation? Ineffective CAPA?
4. Other factors