ChecklistEU

EU Medical Device Regulation (MDR) 2017/745 Compliance Checklist

Turn MDR obligations into owners, evidence, and release gates.

Use this checklist per device family to build an audit-ready MDR operating system (technical documentation, clinical evaluation, PMS/vigilance, UDI/EUDAMED).

Author
Sorena AI
Published
Feb 22, 2026
Updated
Feb 22, 2026
Sections
7

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 22, 2026
Updated Feb 22, 2026
Overview

This MDR compliance checklist is designed for execution, not awareness. Use it to assign ownership, define evidence outputs, and create must be true release gates before placing a device on the market or shipping a software update. Treat it as a living control set that evolves with intended purpose, claims, design changes, suppliers, and post-market signals.

Section 1

How to run the checklist (so it produces audit-ready outputs)

Run this checklist per device family. For each line item, record: owner, artifact link, last updated date, review/approval, and acceptance criteria.

If you use a notified body route, this structure also helps you package an application that's coherent and reviewable.

  • Outcome-based: every item results in a concrete artifact (memo, procedure, report, registry record).
  • Traceable: link claims, risks, controls, tests, labeling, and PMS signals.
  • Release-gated: define conditions that must be met before each release, update, or market expansion.
Recommended next step

Turn EU Medical Device Regulation (MDR) 2017/745 Compliance Checklist into an operational assessment

Assessment Autopilot can take EU Medical Device Regulation (MDR) 2017/745 Compliance Checklist from turning this checklist into an operational workflow to a reusable workflow inside Sorena. Teams working on EU Medical Device Regulation (MDR) 2017/745 can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 2

A. Scope, role, and classification (highest-leverage MDR decisions)

Lock down the decisions that drive everything else: intended purpose, software qualification, economic operator role, and Annex VIII classification.

Output: scope memo + classification memo + conformity assessment route decision.

  • Intended purpose statement + claim inventory (label, IFU, marketing, UI outputs).
  • Borderline/exclusion analysis; Annex XVI check + common specifications if applicable.
  • Economic operator role map (manufacturer/authorised representative/importer/distributor) and contracts.
  • Annex VIII classification memo (include software Rule 11 analysis where relevant).
  • Conformity assessment route decision (Annex IX/X/XI) + notified body engagement plan if required.
Section 3

B. QMS and governance (build a system that survives audits and change)

MDR expects an operating system: documented processes, competent roles, change control, and post-market feedback loops. For software, your QMS must support frequent updates without losing traceability.

Output: procedures + training + audit plan + management review inputs tied to PMS.

  • PRRC appointment and responsibilities (where required), including release sign-off gate.
  • Document control, design control, and change control (incl. software/cybersecurity changes).
  • Supplier controls (critical suppliers, subcontractors) and purchasing controls linked to risk.
  • Complaint handling and vigilance procedures with escalation paths and deadlines.
  • Internal audits and management review cadence based on risk and post-market signals.
Section 4

C. Technical documentation (Annex II/III) + GSPR checklist (Annex I)

Technical documentation is your evidence backbone. Build an index that stays consistent across variants, accessories, and changes.

Output: Annex II/III technical file + a traceable GSPR checklist (Annex I) linked to evidence.

  • Device description/specification, variants, accessories; intended purpose and indications/contraindications.
  • Design and manufacturing information (including critical processes and supplier dependencies).
  • GSPR checklist mapped to risk controls, V&V reports, and labeling/IFU claims.
  • Verification/validation evidence (bench, software, usability, performance, biocompatibility where applicable).
  • Labeling, IFU, packaging, and UDI carrier placement controls.
Section 5

D. Clinical evaluation and clinical evidence (Annex XIV)

Clinical evaluation is the structured justification that your device is safe and performs as intended for the target population, with risks acceptable relative to benefits.

Output: clinical evaluation plan + CER + PMCF plan/evaluation where required.

  • Clinical claims, endpoints, and state of the art baseline; acceptability thresholds and benefit-risk rationale.
  • Clinical data strategy: investigations, literature, real-world evidence; equivalence approach if used.
  • CER structure aligned to MDCG templates; update triggers and periodic review plan.
  • PMCF plan and evaluation report where required, with responsibilities and analysis methods.
  • SSCP content plan and publication workflow where applicable.
Section 6

E. Post-market surveillance (PMS) and vigilance

PMS and vigilance are operational capabilities. They connect real-world signals back into design, labeling, risk management, and CAPA.

Output: PMS plan, PMS report/PSUR, signal/trend reporting, and FSCA/recall readiness.

  • PMS plan (Annex III): data sources, KPIs, signal detection, responsibilities.
  • PSUR/PMS reporting cadence and review; management review inputs from PMS signals.
  • Vigilance reporting workflow for serious incidents and field safety corrective actions (FSCA).
  • Trend reporting and safety signal escalation integrated with CAPA effectiveness checks.
  • Post-market cybersecurity monitoring (for connected/software devices) integrated with change control.
Section 7

F. UDI and EUDAMED readiness

UDI and EUDAMED impact traceability, labeling, and device data management. Plan these as operations, not as end-of-project paperwork.

Output: actor registration, device/UDI records, submission and update governance, and periodic data quality checks.

  • UDI strategy: Basic UDI-DI, UDI-DI and UDI-PI assignment rules; labeling/packaging controls.
  • EUDAMED actor registration readiness (roles, delegates, identifiers).
  • Device/UDI database submissions and update procedures tied to design/change control.
  • Certificate and notified body data readiness (where applicable).
  • Internal audits on traceability data accuracy (label and registry and QMS).
Primary sources

References and citations

Related guides

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