FAQEU MDR

EU MDR PMCF plan and report

PMCF is the MDR post-market clinical follow-up process for proactively collecting and evaluating clinical data from a CE-marked device used within its intended purpose.

Use this FAQ to align the PMCF plan, PMCF activities, clinical-evaluation updates, PMS outputs, and technical-documentation evidence.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
2

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

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

An EU MDR PMCF plan should show how the manufacturer will collect and evaluate post-market clinical data to confirm safety, performance, clinical benefit where applicable, residual-risk acceptability, benefit-risk acceptability, emerging risks, side-effects, contraindications, and possible systematic misuse or off-label use.

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2 of 2 questions
Question 1

What should the PMCF plan cover?

PMCF is a continuous process that updates the clinical evaluation under Article 61 and Annex XIV, Part B. It must be addressed in the manufacturer's PMS plan and performed under a documented PMCF plan.

The plan should identify the device and covered variants, intended purpose, users, patient population, indications, contraindications, warnings, classification, expected lifetime, and the PMCF objectives for that device. It should also reference the clinical evaluation report and risk management file so the post-market clinical questions being followed are clear.

  • Define general methods such as clinical experience review, user feedback, scientific literature screening, and other clinical-data sources.
  • Define specific methods where needed, such as suitable registries, PMCF studies, real-world evidence analyses, healthcare-professional surveys, patient or user surveys, and case-report review.
  • For each activity, state the source of the need, objective, rationale, known limitations, data quality expectations, endpoints or analysis approach, and justified schedule for analysis and reporting.
  • Reference applicable common specifications, harmonised standards used by the manufacturer, and PMCF guidance where they support the plan.
Citations
Regulation (EU) 2017/745 on medical devices

Binding MDR source for Article 61, Article 83-86, Annex III, and Annex XIV Part B requirements on clinical evaluation, PMS, PMCF planning, PMCF reports, PSUR content, and technical documentation.

MDCG 2020-7 - PMCF plan template

MDCG template source for PMCF plan sections, device description, PMCF methods and activities, links to the clinical evaluation report and risk management file, equivalent or similar device data, standards or guidance references, and report timing fields.

Question 2

What evidence should be retained?

Keep evidence showing that PMCF was planned, performed, analysed, and used to update the device file. The retained record should let a reviewer trace each PMCF activity from the clinical question or risk being monitored to the data source, method, result, conclusion, and follow-up action.

The PMCF evaluation report becomes part of the clinical evaluation report and technical documentation. PMCF conclusions must be considered in the clinical evaluation and risk management; where PMCF identifies a need for preventive or corrective measures, the manufacturer must implement them.

  • Retain the PMCF plan, revision history, activity table, protocols, search strategies, registry or study summaries, survey instruments, case-review records, and analysis outputs.
  • Retain the PMCF evaluation report with links to the clinical evaluation report, risk management file, PMS plan, PMS report or PSUR where applicable, and any preventive or corrective action records.
  • Keep the rationale for method choice, sample size or data sufficiency, endpoints, comparator or state-of-the-art references, known limitations, missing-data handling, and acceptance criteria where used.
  • If no PMCF activity is planned or an activity is limited, retain the MDR-grounded justification and the evidence showing why the residual clinical questions remain adequately controlled.
Citations
Regulation (EU) 2017/745 on medical devices

Binding MDR source for the requirement that PMCF findings are documented in a PMCF evaluation report, included in the clinical evaluation report and technical documentation, and considered for clinical evaluation, risk management, and preventive or corrective measures.

Recommended next step

Review PMCF evidence before notified-body questions

Map the PMCF plan, PMCF evaluation report, clinical evaluation, PMS output, PSUR where applicable, and technical-documentation evidence before the next MDR review.

Primary sources

References and citations

health.ec.europa.eu
Referenced sections
  • MDCG template source showing notified-body review prompts for PMS plan, PMS report where relevant, PMCF plan, PMCF report where relevant, PSUR if available, and clinical-evaluation update planning.
"PMS, PMCF and the plan for updates"
health.ec.europa.eu
Referenced sections
  • MDCG template source for PMCF plan sections, device description, PMCF methods and activities, links to the clinical evaluation report and risk management file, equivalent or similar device data, standards or guidance references, and report timing fields.
"The PMCF plan shall be part of the post-market surveillance plan."
eur-lex.europa.eu
Referenced sections
  • Binding MDR source for the requirement that PMCF findings are documented in a PMCF evaluation report, included in the clinical evaluation report and technical documentation, and considered for clinical evaluation, risk management, and preventive or corrective measures.
"document the results in a PMCF evaluation report"
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