- Which compliance frameworks apply to Software as a Medical Device?
- Most SaMD teams work to ISO 13485 for the quality system, ISO 14971 for risk, IEC 62304 for the software lifecycle and IEC 62366-1 for usability, plus FDA QSR in the United States and EU MDR — usually Rule 11 — in Europe. AI-enabled SaMD adds GMLP expectations and, for the EU market, the AI Act.
- Does an AI tool used in regulatory work need its own device certification?
- Not usually. Software that supports internal regulatory strategy and documentation is not itself a medical device, because it has no medical purpose for a patient. What matters is that it produces records you can defend: attributable, traceable and reviewable outputs that fit your own quality system.
- What is the difference between FDA QSR and ISO 13485?
- ISO 13485 is a voluntary international quality-management standard; FDA QSR is U.S. law. Since the Quality Management System Regulation aligned 21 CFR Part 820 with ISO 13485, most manufacturers run one quality system and document the remaining U.S.-specific requirements, such as certain record and complaint provisions, on top of it.
- What does 21 CFR Part 11 require from software used in regulated work?
- Validated systems, secure and attributable audit trails, controls over who can create or change records, retention that keeps records readable for their required life, and — where signatures are applied — signature manifestations linked to the record they sign.
- How does the EU AI Act interact with EU MDR?
- They stack. An AI-enabled device still needs MDR conformity assessment; the AI Act adds obligations on data governance, technical documentation, transparency, human oversight and post-market monitoring for high-risk AI. In practice the notified-body assessment covers both sets of requirements for medical devices.
- What does ALCOA+ mean in day-to-day practice?
- It means each record shows who produced it, when, from what original source, and remains legible, complete, consistent and available for as long as it is needed. For regulatory decisions that translates into keeping the evidence and the reasoning together, not just the conclusion.