Artifact GuideEU

EU MDR Checklist

This checklist helps organize the evidence needed before a medical device is placed on the EU market or put into service under Regulation (EU) 2017/745.

It turns MDR qualification, classification, conformity assessment, technical documentation, clinical evidence, UDI, EUDAMED, PMS, vigilance, QMS, and legacy-transition checks into owner-ready evidence records.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
7

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

An MDR checklist should prove three things: the product is correctly qualified and classified, the right conformity route and notified-body evidence were used, and the technical file stays current through clinical evaluation, risk management, PMS, vigilance, UDI, EUDAMED, and QMS controls.

Section 1

1. Qualification and role check

Start with the product claim rather than the engineering label. MDR qualification turns on the shown in labels, instructions for use, promotional material, sales claims, and the clinical evaluation. Record whether the item is a medical device, accessory, Annex XVI product without an intended medical purpose, custom-made device, system, procedure pack, software, or a borderline product that needs escalation.

Name the economic-operator role for the evidence pack. The checklist should identify the manufacturer, authorised representative where the manufacturer is outside the Union, importer, distributor, and any person assembling systems or procedure packs. That role map determines who owns technical documentation, registration, UDI, vigilance, and authority-response records.

  • Evidence owner: regulatory affairs owns the qualification memo and role map; product and clinical teams provide claims, , indications, contraindications, and user population.
  • Keep: intended-purpose statement, current label and IFU drafts, marketing claims, product architecture, software function description, accessory rationale, Annex XVI assessment where relevant, and borderline escalation notes.
  • Review trigger: new claim, new intended user, new indication, changed software function, added accessory, changed pack or system configuration, or authority/notified-body question.
Section 2

2. Classification and conformity route

Classify the device under Annex VIII before choosing the conformity route. The record should show the applicable rule, duration of use, invasiveness, body contact, active function, software decision impact, medicinal substance or tissue component, sterile or measuring function, and the reason the highest applicable class was selected.

Use the classification to select the conformity assessment route under Article 52 and Annexes IX, X, or XI. Class IIa, IIb, and III devices generally require a notified body. Most class I devices use manufacturer self-declaration, but sterile class I devices, class I devices with a measuring function, and reusable surgical instruments need notified-body involvement limited to sterility, metrology, or reuse controls. Confirm whether the body is designated for the device scope and whether the application, contract, audit, technical-documentation assessment, surveillance, and certificate records are complete.

  • Evidence owner: regulatory affairs owns the classification rationale; quality owns notified-body applications and certificates; product owners supply device design and intended-use facts.
  • Keep: Annex VIII rule analysis, class conclusion, conformity route decision, notified-body designation scope check, application review, written agreement, audit reports, certificates, limitations, and surveillance actions.
  • Review trigger: changed , changed material or contact duration, new software decision function, sterile/measuring claim, changed notified-body scope, certificate condition, significant design change, or unresolved nonconformity.
Section 3

3. Annex II and Annex III technical documentation

Build the technical file around Annex II and Annex III rather than around a generic document list. The record should identify the device and Basic UDI-DI, , classification rule, design and manufacturing information, checklist, benefit-risk analysis, verification and validation data, clinical evaluation, PMS plan, and PMS outputs. Article 10 requires the manufacturer to retain the technical documentation, declaration, and relevant certificates for at least 10 years after the last covered device is placed on the market, or at least 15 years for implantable devices.

Use standards to support, rather than replace, the file. Where harmonised standards or common specifications are used, record exactly which requirements they cover and where the design uses another solution. The record should let a notified body or competent authority trace each safety and performance claim to design evidence, risk controls, verification, validation, clinical evidence, and PMS updates.

  • Evidence owner: quality owns the technical-documentation index; engineering owns design, verification, validation, cybersecurity, usability, and manufacturing evidence; regulatory owns the matrix and declarations.
  • Keep: Annex II index, Annex III PMS plan and report or , matrix, standards and common-specification mapping, risk-management file, clinical evaluation report, PMCF plan where applicable, labels, IFU, UDI records, and declaration of conformity.
  • Review trigger: new or revised harmonised standard, common specification, design change, manufacturing change, supplier change, complaint trend, serious incident, PMCF result, or notified-body surveillance finding.
Recommended next step

Turn the MDR checklist into an evidence pack

Map your device, class, conformity route, technical documentation, clinical evidence, UDI, EUDAMED, PMS, vigilance, QMS, and legacy-transition records into one owner-controlled MDR evidence pack.

Section 4

4. GSPR, risk, and clinical evidence

Use the checklist as a traceability table. For each applicable Annex I requirement, list the hazard or performance claim, risk-control measure, verification or validation evidence, standard or common specification where used, residual-risk conclusion, and owner.

Clinical evidence should stay connected to and risk. The clinical evaluation plan and report should identify the GSPRs needing clinical data, the target groups, clinical benefits, outcome parameters, literature strategy, clinical investigations or equivalence rationale, favourable and unfavourable data, and PMCF plan where needed.

  • Evidence owner: clinical affairs owns the clinical evaluation and PMCF; risk management owns the risk file and benefit-risk conclusion; regulatory owns the traceability matrix.
  • Keep: risk-management plan and report, benefit-risk determination, matrix, clinical evaluation plan, clinical evaluation report, clinical evidence gap analysis, PMCF plan and evaluation report, and updates feeding back into risk controls and IFU.
  • Review trigger: new clinical data, PMCF finding, complaint trend, newly identified hazard, changed patient population, changed claim, changed state of the art, or notified-body clinical evaluation assessment comment.
Section 5

5. UDI and EUDAMED records

Assign and control Basic UDI-DI, UDI-DI, and UDI production identifiers before release evidence is frozen. The checklist should show the issuing entity, assignment rules, label placement, packaging levels, device registration data, and change controls for events that require a new UDI-DI.

Confirm EUDAMED duties separately from label generation. Since 28 May 2026, the Actor, UDI/Devices, Notified Bodies and Certificates, and Market Surveillance modules have been mandatory under the gradual-rollout provisions. The Clinical Investigations and Vigilance/PMS modules have separate later milestones, so do not describe all six modules as fully mandatory.

  • Evidence owner: regulatory operations owns EUDAMED submissions; supply chain and labelling own UDI carrier implementation; quality owns change control.
  • Keep: Basic UDI-DI logic, UDI-DI assignment records, issuing-entity records, label artwork, packaging hierarchy, EMDN selection, applicable EUDAMED submission evidence, and change assessments for model, sterile status, pack quantity, critical warnings, or contraindications.
  • Registration control: update changed actor-registration data within one week. Confirm the registered data no later than one year after the first submission and every second year after that; keep the EUDAMED confirmation evidence.
  • Review trigger: model or trade-name change, new package quantity, changed sterile or single-use status, new critical warning, changed contraindication, EUDAMED module change, or legacy-device registration need.
Section 6

6. PMS, vigilance, and QMS controls

PMS is a live input into the technical file. The MDR requires manufacturers to proactively collect and review experience from devices on the market, update technical documentation, and use PMS outputs to support corrective and preventive actions, risk management, clinical evaluation, PMCF, and transparency records.

Separate PMS reporting from vigilance reporting. Class I devices need a PMS report; class IIa, IIb, and III devices need PSURs at the MDR frequency. Serious incidents and field safety corrective actions must be reported through the vigilance system within the MDR timelines, with trend reporting where the frequency or severity of non-serious or expected incidents could affect benefit-risk.

  • Evidence owner: quality owns the QMS, CAPA, complaints, PMS, , and vigilance procedures; regulatory affairs owns authority and notified-body communications; medical safety owns incident assessment.
  • Keep: PMS plan, PMS report or , complaint and feedback logs, trend methodology, serious-incident assessments, field safety corrective action files, field safety notices, CAPA effectiveness checks, and notified-body/authority correspondence.
  • Review trigger: complaint cluster, serious incident, field safety corrective action, trend signal, cycle, PMCF result, supplier nonconformity, post-certification surveillance finding, or CAPA effectiveness failure.
Section 7

7. Legacy transition check

Document legacy-device status as a controlled exception rather than a general grace period. For devices relying on the amended Article 120 transition, record the old certificate or declaration basis, continued compliance with the prior Directive, absence of significant design or intended-purpose changes, MDR QMS status, notified-body application status, written agreement status, and which MDR PMS, market surveillance, vigilance, and registration duties already apply.

Use the transition record to drive release and change-control decisions. For covered devices, Regulation (EU) 2023/607 sets 31 December 2027 for specified class III and class IIb implantable devices, and 31 December 2028 for other covered class IIb and class IIa devices, class I sterile or measuring devices, and formerly self-declared devices that now require a notified body. The extension is conditional, including continued Directive compliance, no unacceptable risk, no significant design or intended-purpose change, an MDR QMS by 26 May 2024, a formal notified-body application by 26 May 2024, and a written agreement by 26 September 2024. If any condition is missing, do not assume the later date applies.

  • Evidence owner: regulatory affairs owns the legacy applicability memo; quality owns QMS evidence and change control; commercial operations owns shipment holds tied to transition status.
  • Keep: legacy certificate or declaration, device-category and transition-end-date rationale, Directive compliance and unacceptable-risk assessment, significant-change assessment, MDR QMS evidence, notified-body formal application, written agreement, surveillance transfer evidence, registration records, and PMS/vigilance procedures applying during transition.
  • Review trigger: certificate expiry, significant change, new substitute device, notified-body capacity issue, missed application or written-agreement evidence, QMS gap, or transition date approaching for the device class.
Primary sources

References and citations

health.ec.europa.eu
Referenced sections
  • Supports practical UDI-DI and Basic UDI-DI assignment controls, including examples of changes that can require a new UDI-DI.
"new UDI-DI assignment"
eur-lex.europa.eu
Referenced sections
  • Supports Article 10 QMS obligations, Article 83 PMS system, Article 85 PMS report, Article 86 PSUR, and Articles 87 to 92 vigilance reporting.
"post-market surveillance"
eur-lex.europa.eu
Referenced sections
  • Supports amended MDR transition conditions, including legacy-device categories, QMS condition, notified-body application, written agreement, surveillance transfer, and continued PMS/vigilance/registration duties.
"transitional provisions"
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