What medical device compliance means in 2026

Medical device compliance is the ongoing work of meeting every legal requirement that applies to a device from design through retirement. In the US that means FDA’s requirements under the Federal Food, Drug, and Cosmetic Act and 21 CFR. In Europe it means the Medical Device Regulation (EU) 2017/745 (MDR) or the In Vitro Diagnostic Regulation (IVDR).

The meaning of compliance has shifted in 2026 for three reasons:

  1. The quality system rules changed. FDA’s Quality Management System Regulation (QMSR) took effect February 2, 2026, incorporating ISO 13485:2016 by reference (FDA).
  2. Inspections changed with them. FDA’s revised compliance program, CP 7382.850, now organizes inspections around six QMS areas and evaluates risk management throughout (FDA).
  3. The regulator is stretched. FDA lost roughly 21% of its staff, more than 4,400 people, and device makers report less consistent reviewer feedback (MedTech Dive). Clear, complete documentation matters more when there is less time for back-and-forth.

Compliance across the device lifecycle

FDA lists the basic regulatory requirements device manufacturers must meet: establishment registration, device listing, premarket notification or approval, investigational device exemption for clinical studies, the quality system regulation, labeling requirements and medical device reporting (FDA, Overview of Device Regulation). Mapped to the lifecycle, they look like this:

Lifecycle stageUS (FDA) requirementEU MDR equivalentKey evidence
Classification21 CFR 860; product codesAnnex VIII classification rulesClassification rationale
DesignDesign controls (ISO 13485 clause 7.3 via QMSR)Annex II technical documentationDesign and development file, risk file
ClinicalIDE (21 CFR 812)Clinical evaluation and investigationsClinical evaluation report, study data
Market entry510(k), De Novo or PMAConformity assessment and CE markingSubmission, certificates
RegistrationEstablishment registration and listing (Part 807)EUDAMED actor and device registrationRegistration records
ProductionQMSR (Part 820)QMS per Article 10 and Annex IXProcess validation, device records
LabelingParts 801, 830 (UDI), §820.45Annex I Chapter III, UDILabeling review and release records
PostmarketMDR (Part 803), corrections and removals (Part 806)Vigilance, PMS, PSURComplaint, reporting and trend records

Two details are easy to miss. First, most low-risk devices still carry obligations even if they need no premarket review: FDA notes that “Approximately 572 or 74% of the Class I devices are exempt” from 510(k), but exemptions are limited and most devices remain subject to QMS and reporting rules (FDA). Second, Part 806 requires reports of certain corrections and removals within 10 working days, so postmarket compliance depends on fast decisions backed by good records.

What compliance costs to enter the market

FDA user fees rose again for fiscal year 2027, which began October 1, 2026 (Federal Register):

FeeFY2027 standardFY2027 small business
510(k)$28,653$7,163
De Novo$191,020$47,755
PMA$636,732$159,183
Annual establishment registration$13,785No small business discount

A refused or deficient submission means paying for rework in time as well as fees, which is why submission quality is a compliance issue, not just a regulatory affairs task.

Seven compliance changes to plan for

ChangeDateWhat to do
QMSR in effectFeb 2, 2026Remap procedures to ISO 13485 and Part 820; retire QSR-era checklists
Internal audit, management review and supplier audit reports open to FDAFeb 2, 2026Write reports as if an investigator will read them (FDA QMSR FAQ)
CP 7382.850 inspection modelFeb 2, 2026Organize evidence by the six QMS areas
Computer Software Assurance guidance updatedFeb 3, 2026Apply risk-based assurance to production and QMS software (FDA)
eSTAR mandatory for De NovoOct 1, 2025 (510(k) since Oct 1, 2023)Build submissions in eSTAR and submit through the CDRH Portal (FDA)
EUDAMED mandatory modulesMay 28, 2026Register actors and devices; legacy device registration is due by Nov 28, 2026 (TÜV NORD)
MDUFA VI negotiationReauthorization due by Sep 30, 2027Watch proposed fees and review goals (RAPS)

In Europe, the MDR transition deadlines extended in 2023 still apply, with legacy higher-risk devices due by December 31, 2027 and lower-risk devices by December 31, 2028. A broader MDR and IVDR reform is moving through the legislative process: Emergo by UL reports that the European Parliament’s IMCO and BUDG committees voted in favor in September 2026, with a plenary vote expected in the first quarter of 2027 and adoption targeted for mid-2027 (Emergo). Until it is adopted, comply with the MDR as written.

What happens when compliance fails

FDA classifies inspection outcomes as No Action Indicated (NAI), Voluntary Action Indicated (VAI) or Official Action Indicated (OAI), where OAI means regulatory or administrative action will be recommended (FDA). Observations are recorded on Form FDA 483, and serious or unresolved issues can lead to warning letters, import alerts or injunctions.

Enforcement has not slowed with the staffing cuts. Hogan Lovells counted 19 device quality system warning letters in 2025 through September 4, compared with 12 in the same period of 2024, while noting an “overall decrease in the number of inspections over the past decade” (Hogan Lovells). FDA has also expanded unannounced inspections of foreign facilities (FDA). Fewer inspections, in other words, does not mean lower stakes when one happens.

Medical device compliance program checklist

Governance

  • Regulatory requirements register covering every market you sell in, with an owner per requirement
  • Regulatory intelligence process to track guidance, standards and fee changes
  • Management review covers compliance status, audit results, CAPA and postmarket data

Quality system

  • Procedures mapped to ISO 13485:2016 and Part 820 (QMSR)
  • Risk management (ISO 14971) linked to design, production, complaints and CAPA
  • Software used in production and the QMS assured with a risk-based CSA approach
  • Supplier controls proportionate to risk, with quality agreements in place

Market access

  • Classification rationale documented for each device and market
  • Submissions built in eSTAR and checked for completeness before filing
  • EU technical documentation, clinical evaluation and EUDAMED registration current

Postmarket

  • Complaints assessed for MDR reportability with decisions documented
  • Corrections and removals evaluated against Part 806 timelines
  • EU vigilance, PMS plan and PSUR/PMS report current

Inspection readiness

  • Evidence organized by FDA’s six QMS areas
  • Front-room and back-room roles assigned; 483 response process defined
  • Foreign sites and contract manufacturers ready for unannounced inspections

Check compliance evidence faster

Most compliance gaps are documentation gaps: a procedure that cites the wrong clause, a risk file that was never updated, a complaint without a reportability decision. AI document assessment can read procedures and records against QMSR, ISO 13485 or the EU MDR, flag what is missing, and cite the passage behind every finding.

Run a sample regulatory document assessment on one procedure or technical file. AskDona shows the evidence; your regulatory team decides.

FAQ

What is medical device regulatory compliance? Meeting all legal requirements for a device across its lifecycle, from classification and premarket review to quality systems, labeling and postmarket reporting (FDA).

Is ISO 13485 certification required in the US? No. QMSR incorporates ISO 13485:2016 requirements, but FDA does not require or issue certificates. FDA checks compliance through inspections.

What changed in FDA compliance in 2026? QMSR took effect February 2, 2026, alongside a new inspection compliance program (CP 7382.850) and an updated CSA guidance.

Are low-risk devices exempt from compliance? Many Class I devices are exempt from 510(k) review, but most still must register, list, report adverse events and follow applicable QMS requirements (FDA).

References

All pages opened and checked by October 13, 2026.

SourceTypeDateUsed for
FDA: QS Regulation / QMSRRegulator2026QMSR effective date
FDA: CP 7382.850RegulatorFeb 2, 2026Inspection model
FDA: QMSR FAQRegulator2026Records open to FDA
FDA: Overview of Device RegulationRegulatorCurrentCore requirements
FDA: Classify Your Medical DeviceRegulatorCurrentClass I exemptions
FDA: CSA guidanceRegulator guidanceFeb 3, 2026Software assurance
FDA: CDRH PortalRegulatorCurrenteSTAR dates
FDA: Inspection classificationsRegulatorCurrentNAI/VAI/OAI
FDA: Unannounced foreign inspectionsRegulatorMay 6, 2025Foreign inspections
Federal Register: FY2027 device user feesRegulator2026Fees
MedTech Dive: CDRH workloadsTrade pressApr 1, 2026FDA staffing
Hogan Lovells: Device inspections in 2025Law firm2025Warning letter counts
RAPS: MDUFA VI draft commitment letterProfessional bodyJul 8, 2026MDUFA VI
TÜV NORD: EUDAMED mandatory useNotified body2026EUDAMED deadlines
Emergo by UL: MDR/IVDR revision timingConsultancyOct 9, 2026EU reform status