Artifact GuideEU

EU MDR Clinical Evidence

Clinical evidence under Regulation (EU) 2017/745 is the clinical data and clinical evaluation result that allows a qualified assessment that a device is safe and achieves its intended clinical benefit when used as intended.

This page helps structure the clinical evaluation file, equivalence rationale, clinical investigation decision, PMCF plan, GSPR linkage, and notified-body review package.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
4

Cited legal and guidance references.

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

EU MDR work should connect the device's intended purpose, claims, risk profile, , , and technical documentation. The useful output is not a generic evidence memo; it is a traceable clinical evaluation record that supports the relevant General Safety and Performance Requirements (GSPRs), explains any remaining uncertainty, and is ready for notified-body assessment where a notified body is involved.

Section 1

Build the clinical evaluation around the MDR evidence question

Start with Article 61 and Annex XIV: identify the GSPRs that need , specify the device's intended purpose and target groups, define measurable clinical benefits and safety endpoints, and justify the level of needed for the device's characteristics, classification, intended purpose, and risks.

The clinical evaluation should then show the route used to reach the conclusion: available for the device, clinical data for an equivalent device where equivalence is demonstrated, clinical data from similar devices where it informs state of the art or study design, and any new clinical investigation data needed to close evidence gaps.

Keep the terms separate in the working file. are the safety or performance information generated from a device's use, clinical investigations, or qualifying published experience. is the clinical data plus the clinical evaluation results that are sufficient, in amount and quality, to support conformity. Relevance, appraisal quality, and traceability to the intended purpose and GSPRs determine whether a large literature set supports sufficient clinical evidence.

  • Define the device version, Basic UDI-DI where relevant, intended users, patient population, indications, contraindications, claims, accessories, and configurations covered by the evaluation.
  • Map each clinical claim and relevant GSPR to the data source that supports it, including literature searches, clinical investigation reports, PMS and data, registries, user feedback, complaints, vigilance information, and risk-management outputs.
  • Include both favourable and unfavourable data, then explain how data quality, relevance, bias, follow-up, sample size, and transferability affect the clinical conclusion.
  • Document the clinical evaluation report as part of the technical documentation, together with the , non-clinical evidence, risk-management links, and any unresolved questions for .
Section 2

Decide when clinical investigations or other clinical data are enough

For implantable and class III devices, Article 61(4) starts from a clinical-investigation requirement, then provides defined exceptions. The CER should identify the exact route: modification of a device already marketed by the same manufacturer with demonstrated equivalence and notified-body endorsement; reliance on another manufacturer's MDR device under the Article 61(5) contract and conditions; or one of the Article 61(6) device categories where sufficient and any applicable common specification support the exception. The exception does not remove the duty to conduct and update the clinical evaluation.

Where a clinical investigation is needed, Annex XV expects a scientifically sound investigation plan aligned with the clinical evaluation plan and designed to confirm or refute the manufacturer's claims on safety, performance, clinical benefits, and benefit-risk. The investigation report should critically evaluate all collected data, including negative findings.

  • For clinical investigation reliance, keep the approved clinical investigation plan, endpoint rationale, statistical justification, monitoring records, investigator access to technical and , training evidence, and final clinical investigation report.
  • For literature or other existing , keep the search protocol, search report, selection criteria, appraisal method, full references, excluded-data rationale, and analysis showing relevance to the device and intended purpose.
  • For any decision not to perform a clinical investigation, identify the exact Article 61 paragraph, document sufficient , record any notified-body endorsement or contract required by that route, address applicable common specifications, and assign remaining questions to PMS or .
  • For Article 61(10) arguments based on non-clinical methods, keep the risk-management basis, the interaction-with-the-body analysis, intended clinical performance, manufacturer claims, and the technical-documentation justification; do not use that route for class III or implantable devices.
Section 3

Use equivalence only when the MDR criteria and data access are documented

Equivalence is not a shortcut to avoid evidence. Annex XIV requires technical, biological, and clinical characteristics to be considered, and MDCG 2020-5 emphasizes that differences must be fully identified, assessed, and scientifically justified so they do not create clinically significant differences in safety or clinical performance.

For each presumed equivalent device, keep a separate equivalence table and do not assemble equivalence from different devices for different features. Sufficient access to the data supporting equivalence is required under Annex XIV. The additional Article 61(5) contract for full, ongoing access to another manufacturer's technical documentation applies when an implantable or class III device uses that specific route to avoid a new clinical investigation; it should not be described as a universal contract requirement for every equivalence analysis.

  • Compare clinical characteristics: same clinical condition or purpose, similar severity and disease stage, same body site, similar population, same kind of user, and similar relevant critical performance for the expected clinical effect.
  • Compare technical characteristics: design, specifications, properties, deployment method, principles of operation, critical performance requirements, software algorithms, and other characteristics relevant to safety or performance.
  • Compare biological characteristics: materials or substances in contact with the same tissues or body fluids, duration of contact, release characteristics, processing effects, and biological-safety implications.
  • Document the data-access source, version or generation of the equivalent device, regulatory status, identified differences, scientific justification, and why the data remain relevant to the device under evaluation.
Section 4

Tie PMCF, benefit-risk, and technical documentation together

is a continuous process that updates the clinical evaluation after CE marking. The PMCF plan should state why each activity is needed, which residual clinical uncertainties it addresses, what data quality and quantity are expected, how bias and missing data will be controlled, and when data will be analysed and reported.

The evaluation report should feed back into the clinical evaluation report, the risk-management file, the benefit-risk conclusion, IFU and labelling decisions, SSCP where applicable, PMS outputs, and corrective or preventive action decisions. For class III and implantable devices, Article 61 requires at least annual updates of the PMCF evaluation report and, if indicated, the SSCP; other devices still need lifecycle updates when new evidence or risk information changes the evaluation.

  • Use to confirm safety and performance over the expected lifetime, monitor known side effects and contraindications, identify unknown side effects, analyse emerging risks, check continued benefit-risk acceptability, and detect systematic misuse or off-label use.
  • Reference the clinical evaluation report and risk-management file sections that will monitor; if no relevant section exists, state that explicitly and justify it.
  • Select methods that match the device risk and uncertainty: literature screening, user or patient surveys, registry analysis, real-world evidence, extended follow-up, PMCF studies, or new post-market clinical investigations.
  • Keep the plan, PMCF activity rationale, data-quality assumptions, endpoints, timelines, PMCF evaluation report, and resulting updates inside the technical documentation.
Recommended next step

Turn MDR clinical evidence into a review-ready file

Use Sorena to connect clinical claims, GSPR support, equivalence rationale, PMCF, risk management, and notified-body questions in one cited evidence workflow.

Section 5

Prepare for notified-body review of clinical evidence

Where a notified body reviews the device, expect scrutiny of the clinical evaluation as part of the technical documentation assessment and surveillance. The MDR requires notified bodies to examine clinical evaluation planning, literature methodology, clinical investigations, equivalence, PMS and , clinical evaluation reports, and justifications for not performing clinical investigations or PMCF.

For higher-risk devices subject to clinical evaluation consultation, the notified body's clinical evaluation assessment report can be reviewed by an expert panel. The package should therefore make the benefit-risk conclusion, consistency with intended purpose and medical indications, plan, and residual evidence gaps easy to follow.

  • Provide a reviewer-ready index from each clinical claim to its supporting , GSPR, risk-control record, IFU or SSCP statement, and follow-up item.
  • Flag any unresolved clinical uncertainty, non-conformity, limitation in equivalent-device data access, missing follow-up, or dependency before the notified body has to infer it.
  • Show how is reflected in the information supplied with the device, including warnings, contraindications, user training, intended purpose, claims, and SSCP where applicable.
  • Keep the notified-body questions, deficiency responses, clinical evaluation assessment report conclusions, milestones, certification conditions, and post-certification surveillance actions with the technical file.
Primary sources

References and citations

health.ec.europa.eu
Referenced sections
  • Commission overview used only for the role and designation context of notified bodies that assess conformity before certain devices are placed on the market.
"assess the conformity of certain products"
health.ec.europa.eu
Referenced sections
  • MDCG equivalence guidance used for technical, biological, and clinical comparison criteria, the need for scientific justification, device-by-device equivalence, and access-to-data constraints.
"proper scientific justification"
health.ec.europa.eu
Referenced sections
  • MDCG 2020-6 supports lifecycle clinical evaluation and the expectation that clinical data continue to demonstrate safety, performance, and benefit-risk acceptability.
"clinical evaluation is a process"
eur-lex.europa.eu
Referenced sections
  • Annex VII and Annex IX ground notified-body assessment of clinical evaluation, clinical evidence, PMCF, benefit-risk, CEAR conclusions, and expert-panel consultation for certain devices.
"review the clinical evidence presented"
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