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Record STMT-WFE5EBFAdvisory

Interplay between the Medical Devices Regulation (MDR) & In vitro Diagnostic Medical Devices Regulation (IVDR) and the Artificial Intelligence Act (AIA)

Guidelines Institutional policyEuropean Unionadopted

This guidance document clarifies the interplay between the European Union Medical Devices Regulation (MDR), In Vitro Diagnostic Medical Devices Regulation (IVDR), and the Artificial Intelligence Act (AIA) for medical device manufacturers. Endorsed by the Artificial Intelligence Board and the Medical Device Coordination Group, it addresses frequently asked questions concerning the scope, classification, quality management, data governance, technical documentation, transparency, human oversight, conformity assessment, and post-market monitoring of medical device artificial intelligence.

Summary and content fields are drawn from the document text and are pending editorial review.

Who issued it

Artificial Intelligence BoardRegulator
Lead issuer
Medical Device Coordination GroupRegulator
Co-issuer
Legal forceAdvisory
Under whose authorityInstitutional policy
Judged fromfull text

Who it governs

CompaniesRegulatorsAI developers and providersAI deployers and usersResearchers and academics

This document is primarily aimed at medical device manufacturers, notified bodies, and competent authorities navigating dual compliance under the MDR/IVDR and the AIA.

Sectors
Healthcare · medical devices and in vitro diagnostic medical devicesTelecommunications and digital services · artificial intelligence software

What the document contains

What's covered

This document covers the joint application of the EU Artificial Intelligence Act and the Medical Devices/In Vitro Diagnostic Medical Devices Regulations. It provides answers regarding product classification, quality management systems, data governance, technical documentation, transparency, human oversight, clinical evaluations, conformity assessments, substantial modifications, and post-market surveillance for medical device artificial intelligence.

What's missing

The document does not provide final binding interpretations of Union law, nor does it replace official European Commission horizontal guidelines or future implementing acts under development.

Key takeaways
  • The AIA complements the MDR and IVDR by introducing specific requirements to address health, safety, and fundamental rights risks unique to AI systems used in medical devices.
  • An AI system embedded in a medical device is generally classified as high-risk under the AIA if it acts as a safety component or is itself a medical device subject to third-party conformity assessment under the MDR or IVDR.
  • Manufacturers can integrate AIA quality management, risk management, and technical documentation requirements into their existing MDR/IVDR procedures to avoid duplication.
  • High-risk Medical Device Artificial Intelligence (MDAI) requires robust data governance, transparency, clear human oversight mechanisms, and comprehensive post-market monitoring.
  • Pre-determined changes assessed during initial conformity assessment do not constitute substantial modifications requiring a new conformity assessment under the AIA.
Outline
· I. Scope of application and classification
· II. Requirements
  - 1. Management Systems
  - 2. Data Governance
  - 3. Technical Documentation
  - 4. Transparency and human oversight
  - 5. Accuracy, Robustness and Cybersecurity
· III. Clinical /Performance Evaluation and Testing
· IV. Conformity assessment
· V. Substantial Modification/significant change
· VI. Post-market monitoring
· VII. Other questions
IssuedJune 2025
Length10,656 words
FormatNot recorded
Scoperegional

How it scores

Pending review

Each score is backed by a quote verified against the document text. Editorial review has not yet confirmed them.

Fairness

4/5

Non-discrimination and equitable treatment

The AIA requires high-risk MDAI manufacturers to implement data governance and management practices appropriate for the claimed intended purpose, including with a view of possible biases

2. Data Governance

screening score · 2026-10-23

Human Dignity

2/5

Respect for the inherent worth of persons

The AIA complements the MDR/IVDR by introducing requirements to address hazards and risks for health, safety and fundamental rights specific to AI systems.

Introduction

screening score · 2026-10-23

Human Oversight

4/5

Humans remain in control of consequential decisions

The AIA emphasizes the importance and sets a legal obligation on the manufacturer to design and develop AI systems, including high-risk MDAI, with appropriate human oversight mechanisms.

4. Transparency and human oversight

screening score · 2026-10-23

Privacy

2/5

Protection of personal data and private life

The data governance and management practices, in the case of personal data, should be fully compliant with the GDPR provisions and include transparency about the original purpose of the data collection.

2. Data Governance

screening score · 2026-10-23

Transparency

4/5

Openness about how AI systems work and are used

Under the AIA, transparency is a core requirement for high -risk MDAI. It introduces on providers a legally binding requirement to design and develop high-risk MDAI in such a way as to ensure that operation of high-risk MDAI is sufficiently transparent

4. Transparency and human oversight

screening score · 2026-10-23

Enforcement

4/5

Consequences and compliance mechanisms with real force

In accordance with Article 43(4) of the AIA, high-risk MDAIs that have been subject to a conformity assessment procedure shall undergo a new conformity assessment procedure in the event of a substantial modification

V. Substantial Modification/significant change

screening score · 2026-10-23

Impact Assessment

4/5

Required assessment of an AI system's risks/impacts before or during use

The MDR and IVDR require manufacturers to validate MDAI outputs through rigorous testing in the form of clinical or performance evaluation to ensure compliance

III. Clinical /Performance Evaluation and Testing

screening score · 2026-10-23

Topics

medical_devices artificial_intelligence_act quality_management conformity_assessment post_market_monitoring data_governance