Notified Bodies under EU MDR are increasingly aligning their audits with IEC 81001-5-1 and IEC 62304 cybersecurity processes, layered on top of MDCG 2019-16 guidance. If you have an FDA-aligned SPDF, the gap to a clean CE technical file is smaller than it looks — but you'll need explicit traceability between security risk control measures and design outputs, plus evidence of post-market vulnerability handling tied to your PMS plan.
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QMSR replaces 21 CFR 820 — what changes for cybersecurityFDA's Quality Management System Regulation harmonizes Part 820 with ISO 13485. Cyber design controls and CAPA expectations carry over with subtle scoping changes.
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Two years of Section 524B: what FDA reviewers are pushing back onPatterns from recent deficiency letters: weak SBOM hygiene, missing VEX statements, and CVD policies that exist on paper but have no real intake.
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