Design control in one paragraph

Design control is the set of planned, documented activities that turn user needs into a safe, effective device: planning, inputs, outputs, reviews, verification, validation, transfer, change control and a design file that proves it all happened. Congress gave FDA the authority in 1990, when the Safe Medical Devices Act “authorized FDA to add Design Controls” to device GMP requirements, and the rule took effect in 1997 (FDA, QMSR Design and Development).

2026 is the biggest change since then. On February 2, 2026, the Quality Management System Regulation (QMSR) replaced 21 CFR 820.30 with ISO 13485:2016 clause 7.3, incorporated by reference. FDA also withdrew its 1997 Design Control Guidance on the same day (FDA, Withdrawn guidance).

Who must apply design controls

Under 21 CFR 820.10(c), design and development requirements apply to “All Class II and Class III medical devices” and to Class I “Devices automated with computer software,” plus a short list of named Class I devices (FDA). Most Class I devices remain exempt, but software-driven ones are not.

The design control process under ISO 13485 clause 7.3

  1. Plan (7.3.2). Define stages, reviews, responsibilities, “traceability methods, and resources needed.”
  2. Inputs (7.3.3). Requirements that are “complete, unambiguous, able to be verified or validated, and not in conflict with each other,” including regulatory and risk management requirements.
  3. Outputs (7.3.4). Specifications that “Meet the input requirements” and “Contain or reference acceptance criteria.”
  4. Review (7.3.5). “Use an appropriate team to systematically review” the design at suitable stages and record actions.
  5. Verification (7.3.6). Show outputs meet inputs, with documented methods, criteria and statistical techniques.
  6. Validation (7.3.7). Show the device meets intended use on representative product; “Must be completed prior to release.”
  7. Transfer (7.3.8). Confirm outputs are “suitable for manufacturing before becoming final production specifications.”
  8. Changes (7.3.9). “Determine the significance of the change” and review, verify or validate, and approve before implementation.
  9. File (7.3.10). Keep a design and development file for each device type or family.

Quoted phrases from FDA, QMSR Design and Development. Risk management (clause 7.1 and ISO 14971) runs through every step rather than sitting beside it.

How FDA inspects design now

FDA retired the Quality System Inspection Technique (QSIT) when the QMSR took effect (AABB). Under compliance program 7382.850, FDA presentation slides show that baseline surveillance and PMA preapproval inspections evaluate, at minimum, design inputs, outputs, review, verification, validation, software validation and transfer (FDA). Investigators also “Review manufacturer’s risk management documentation” first.

That makes risk the entry point. In early QMSR inspections, an FDA official said “Risk management is the top observation” (RAPS). Design and risk files that do not match will show up quickly. Common disconnects include “Missing hazards from risk assessments” and “Failing to connect CAPA actions with design controls” (Naveen Agarwal).

Recent enforcement signals

SignalWhat it shows
Covington counted design control violations “in seven letters” from January to March 2026 (Covington)Design remains a steady warning letter topic
January 2026 letter: the “design transfer process did not ensure that performance specifications” were met (FDA, Abbott Diabetes Care)Transfer to external sites is examined
March 2026 letter: verification “only performed on a single female luer connector” (FDA, Medline Industries)Family coverage claims need a rationale

These inspections predated February 2, 2026 and cite 820.30.

Design control and agile development

Design control does not require waterfall development. AAMI TIR45, updated in 2023, guides teams on applying agile methods while staying aligned with “FDA 21CFR820, ISO 13485” and IEC 62304, including “streamlining approval processes and signature requirements” and integrating “cybersecurity, risk management, design validation, and human factors/usability” (AAMI). The test is the same either way: can you show the records each clause requires?

Design control compliance checklist

  • Design procedures reference the QMSR and ISO 13485 clause 7.3, not 820.30 or the withdrawn 1997 guidance
  • Scope under 820.10(c) confirmed, including software-driven Class I devices
  • Design and development plan with traceability methods
  • Inputs verifiable and linked to risk management outputs
  • Outputs with acceptance criteria and essential characteristics
  • Independent design reviews recorded at defined stages
  • Verification and validation plans with statistical rationale
  • Design transfer evidence, including suppliers and external sites
  • Design change significance assessed and documented
  • Risk file and design file consistent; CAPA feeds design changes
  • Design and development file complete per device type or family

Assess design control records against clause 7.3

AskDona reviews design plans, input and output specifications, review minutes and test reports against ISO 13485 clause 7.3, the QMSR or your own procedure, flags missing records and inconsistencies between design and risk files, and cites the passage behind every finding.

Run a sample design control assessment on one active design project. AskDona shows the evidence; your teams decide.

FAQ

What is design control? A documented process for designing medical devices so they meet user needs and requirements, covering planning through design changes.

Is 21 CFR 820.30 still in effect? No. Since February 2, 2026, design controls follow ISO 13485 clause 7.3 as incorporated into the QMSR.

Which devices need design controls? Class II and Class III devices, Class I devices automated with software and certain listed Class I devices (FDA).

Can I use agile development under design controls? Yes. AAMI TIR45 describes how (AAMI).

How does FDA inspect design controls now? Under compliance program 7382.850, starting from risk management and evaluating design elements from inputs to transfer (FDA).

References

All pages opened and checked by October 14, 2026.

SourceTypeDateUsed for
FDA: QMSR Design and Development (slides)Regulator training2026Clause 7.3, 820.10(c)
FDA: Withdrawn guidanceRegulatorCurrent1997 guidance withdrawn
AABB: FDA implements QMSRProfessional bodyFeb 4, 2026QSIT retired
FDA: QMSR risk-based inspections (slides)RegulatorApr 1, 2026CP 7382.850 design elements
RAPS: Top QMSR observationsProfessional bodyMay 14, 2026Risk management findings
Naveen Agarwal: Risk and design disconnectsExpert newsletterOct 23, 2024Disconnects
Covington: Device warning letters Q1 2026Law firmMay 15, 2026Design control letters
FDA warning letter: Abbott Diabetes CareRegulatorJan 23, 2026Design transfer
FDA warning letter: Medline IndustriesRegulatorMar 25, 2026Verification coverage
AAMI: TIR45:2023Standards body2023Agile