Why IVDs need their own map

In vitro diagnostics share much with medical devices, including ISO 13485 quality systems, but the EU regulates them under a separate regulation with its own classes and deadlines. In 2026 the EU IVDR is where most of the pressure sits, and Japan and the US cover IVDs inside their broader frameworks.

The IVD regulatory map at a glance

AreaEuropean UnionUnited StatesJapanGlobal
Core lawIVDR 2017/746FD&C Act and 21 CFR device rulesPMD ActIMDRF (IVD classification among tracked topics)
Quality systemIVDR Article 10(8) QMS and harmonised ISO 13485QMSR, 21 CFR 820QMS Ordinance (MO169), which covers medical devices and IVD reagentsISO 13485
Risk managementIVDR Annex IQMSRQMS OrdinanceISO 14971
Classification and interpretationMDCG guidance, including MDCG 2020-16 rev.5FDA guidancePMDA guidelinesIMDRF documents
SoftwareMDCG guidanceFDA guidancePMDA guidanceIEC 62304
Registration databaseEUDAMEDFDA databases——
Inspection and enforcementNotified bodies and competent authoritiesForm 483, warning lettersPMDA and prefectural inspections—

The IVDR deadline calendar

Regulation (EU) 2024/1860 extended the IVDR transition for legacy devices, on conditions: continued compliance with the old directive, no significant change in design or intended purpose, and an IVDR QMS by 26 May 2025.

IVDR classApply to notified body byWritten NB agreement byLegacy deadline
Class D26 May 202526 September 202531 December 2027
Class C26 May 202626 September 202631 December 2028
Class B and class A sterile26 May 202726 September 202731 December 2029

As of late October 2026, the class C agreement milestone has just passed, and class B and A sterile manufacturers have about seven months to apply.

Other 2026 changes for IVD makers

  • MDCG 2020-16 rev.5 on IVDR classification rules (September 2026).
  • EUDAMED: four modules mandatory since 28 May 2026; MDCG 2026-4 covers summaries of safety and performance in EUDAMED.
  • US QMSR effective 2 February 2026, with ISO 13485:2016 incorporated by reference.
  • EU simplification proposal (16 December 2025) would amend the IVDR too, but is not yet law.

AI use terms for IVD sources

SourceAI and RAG use
IVDR, MDCGCC BY 4.0 with attribution; only the Official Journal is authentic; keep MDCG separate
EUDAMEDCheck required: operator and personal data
FDA regulations and guidancePublic domain unless noted
PMDA guidelinesPDL1.0, but crawling and bulk download prohibited
IMDRFInternal, non-commercial use only without permission
ISO 13485, ISO 14971, IEC 62304No AI use without permission or an AI-permitted licence

Building an IVD knowledge base

  1. Make the IVDR, with CELEX and consolidation date, the EU core.
  2. Build the deadline table from Regulation 2024/1860 and tag each product by class.
  3. Add MDCG 2020-16 rev.5 and archive rev.4.
  4. Store the 2025 proposal separately as “proposed.”
  5. Use your own QMS documents and ISO clause numbers instead of ISO text.
  6. Set reminders for 26 May 2027 and 26 September 2027 (class B and A sterile).

How AskDona helps

AskDona checks your IVD technical documentation and performance evaluation reports against the IVDR and MDCG guidance, and compares your portfolio with the class-specific deadlines. Each finding cites the article, CELEX, and version used.

Run a sample IVDR transition readiness check

AskDona shows the evidence; your regulatory team decides.

Editor’s note. This article is general information, not legal advice. Status and terms summarize the detailed articles linked above, each checked against official or primary pages by October 26, 2026.

FAQ

What is the next IVDR milestone? Class B and class A sterile legacy devices must apply to a notified body by 26 May 2027.

When does the class D transition end? 31 December 2027.

Does Japan’s QMS Ordinance cover IVDs? Yes. It covers medical devices and in vitro diagnostic reagents.

Can I index MDCG IVD classification guidance in an AI tool? Yes, under CC BY 4.0 with attribution, kept separate from the IVDR text and labeled nonbinding.

References

All pages opened and checked by October 26, 2026. Each linked article lists its own primary sources.

SourceWhat it supports
HPRA: IVDR transitional provisionsDeadlines, milestones, conditions
Regulation (EU) 2024/1860Amending act
European Commission: New regulationsIVDR applicable from 26 May 2022
European Commission: MDCG guidanceMDCG 2020-16 rev.5, MDCG 2026-4
European Commission: EUDAMED overviewMandatory modules
FDA: QMSRQMSR effective date
IMDRF Document Implementation Report 2026IVD classification among tracked topics; terms
ISO: Licence agreementAI restrictions