classifies MDR software that provides information for diagnosis or therapeutic decisions, monitors physiological processes, or falls into the residual software class.
This page helps document whether software is , which branch applies, what conformity route follows, and what clinical and change evidence belongs in the file.
MDR classifies qualified ; it is not a scope test for every health app. First decide whether the software has its own medical purpose. Software that only drives or influences another device follows Annex VIII implementing rule 3.3 and falls in the same class as that device, while accessory software is classified in its own right. For software classified under Rule 11, document the intended purpose, decision impact, physiological monitoring function, and any other applicable Annex VIII rule.
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Section 1
Decide whether the software is medical device software
Start with the MDR Article 2(1) medical device definition and the manufacturer's intended purpose. The MDR expressly includes software when it is intended for medical purposes such as diagnosis, prevention, monitoring, prediction, prognosis, treatment, alleviation, investigation, replacement, modification, or providing information by in vitro examination of human specimens.
MDCG 2019-11 Rev.1 narrows the practical test: software must have a medical purpose on its own to qualify as . The same guidance says hosting location does not decide the question; cloud software, mobile apps, desktop software, and software embedded in a hardware device can all qualify if the intended purpose and function meet the medical-device test. The risk of harm from software use is not itself a qualification criterion.
Exclude functions that merely store, archive, communicate, compress without loss, or perform simple search unless the software also processes, analyses, creates, or modifies medical information for a medical intended purpose. Separately record any software that drives or influences a hardware medical device because it may be covered as a part, component, or accessory even if it does not have its own medical purpose.
Evidence input: intended purpose from labels, instructions for use, promotional statements, product requirements, clinical evaluation scope, and release notes.
Qualification decision: , software driving or influencing a device, accessory software, IVDR software, Annex XVI-related software, or out-of-scope operational software.
Non-qualifying examples to document carefully: invoicing, staff planning, messaging, backup, simple search, unmodified storage, and administrative dashboards without a medical intended purpose.
June 2025 revision explaining medical device software qualification, intended-purpose and module scope, non-qualifying functions, software location, risk as a non-qualification criterion, and software that drives or influences a device.
Software must have a medical purpose on its own
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Section 2
Apply the Rule 11 classification branches
For qualified MDR , apply by function and foreseeable decision impact. Software that provides information used for diagnosis or therapeutic decisions starts at class IIa, but moves to class III when those decisions may cause death or irreversible deterioration of health, and to class IIb when they may cause serious deterioration of health or surgical intervention.
Software intended to monitor physiological processes is class IIa. It becomes class IIb when it monitors vital physiological parameters and the nature of variation could create immediate danger to the patient. All other software is class I, unless another Annex VIII rule or implementing rule produces a higher class.
MDCG 2021-24 Rev.1 warns that software is an and should not be reviewed only in the context of . Keep a short cross-check for active therapeutic, diagnosis and monitoring, closed-loop, and hardware-control rules when the software controls therapy, influences a class IIb active therapeutic device, monitors an active implantable device, or significantly determines patient management. If several Annex VIII rules or sub-rules apply to the intended purpose, implementing rule 3.5 requires the strictest one that results in the higher classification.
Diagnosis or therapy branch: name the decision, decision-maker, patient condition, data inputs, software output, and the harm scenario if the output is wrong or unavailable.
Physiological monitoring branch: identify the physiological process, whether it is vital, and whether variations could immediately endanger the patient.
Residual branch: explain why the software is still qualified as but does not provide decision information or monitor physiological processes within the higher branches.
Connect the software class to the conformity route
classification changes the market route. Class IIa, class IIb, and class III software require notified-body involvement under MDR Article 52. Class III software follows Annex IX or Annex X plus Annex XI. Class IIb software may follow Annex IX with technical documentation assessed for at least one representative device per generic device group, or Annex X plus Annex XI. Class IIa software may follow Annex IX with technical documentation assessed for at least one representative device for each category of devices, or Annex II and Annex III technical documentation plus Annex XI Section 10 or 18.
Class I software can generally be self-declared after the manufacturer draws up Annex II and Annex III technical documentation and issues the EU declaration of conformity, unless another class I feature requiring notified-body involvement applies. A record should state the resulting class, the conformity assessment consequence, and the applicable rule branch.
For software that drives or influences a hardware device, keep the software classification rationale aligned with the hardware device route. If the software changes the operation, output, risk controls, alarms, therapy delivery, or diagnostic information of another device, the conformity route discussion belongs in the combined device file.
Route fields: class, Annex VIII rule branch, notified-body involvement, technical-documentation sampling basis, certificate scope, and declaration of conformity impact.
Release gate: block market-release decisions that cite without identifying the Article 52 route and the technical-documentation package affected by the software version.
Procurement and audit evidence: keep the classification memo, conformity route memo, notified-body correspondence, technical-documentation index, and software release identifier together.
Commission overview explains that notified bodies assess conformity where third-party intervention is required.
assess the conformity of certain products
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Section 4
Build clinical and performance evidence around the software claim
A classification record is not enough to support medical claims. MDR Article 61 requires conformity with relevant general safety and performance requirements, benefit-risk acceptability, and undesirable side-effect evaluation to be based on clinical data providing sufficient clinical evidence. The manufacturer must specify and justify the level of clinical evidence needed for the device characteristics and intended purpose.
For decision-support or monitoring software, the clinical evaluation should tie the algorithm, data inputs, output, target users, patient population, clinical workflow, and claimed clinical benefit to evidence. MDCG 2020-6 describes clinical evaluation as a lifecycle process and highlights the need to incorporate PMS and PMCF data into the clinical evaluation.
When software changes, update the evidence question before release. New or modified algorithms, changed presentation of medical data, closed-loop replacement of user input, new diagnostic or therapeutic features, or new interoperability channels can affect safety, performance, classification, clinical evaluation, and notified-body handling. MDCG 2020-3 addresses whether such changes are significant for legacy devices using the Article 120 transition; it is not a general change-classification rule for every MDR-certified device.
Clinical evaluation inputs: intended purpose, indications, contraindications, target groups, clinical benefit, alternatives, data appraisal, risk management links, verification and validation, and PMS or PMCF outputs.
Software evidence inputs: versioned requirements, architecture, data set description, model or algorithm validation, cybersecurity and usability controls, verification results, known limitations, and release risk assessment.
Change evidence inputs: algorithm change rationale, affected claims, affected diagnostic or therapeutic decisions, vital-parameter monitoring impact, clinical or usability data need, notified-body notification result, and updated technical documentation.
Article 61 and Annex XIV require clinical evaluation, sufficient clinical evidence, justified evidence level, lifecycle updates, and documentation in the technical file.
clinical data providing sufficient clinical evidence
Transitional guidance for legacy devices under MDR Article 120; its software change chart identifies changes that may be significant for continued use of that transition.
Primary MDR source for the medical device definition, Rule 11 classification, Article 52 conformity assessment routes, Article 61 clinical evaluation, and technical-documentation requirements.
Article 2(1) includes software in the medical device definition when the manufacturer intends it for specified medical purposes.
Annex VIII Rule 11 sets the class IIa, IIb, III, and residual class I outcomes for MDR software.
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Article 52 links class I, IIa, IIb, and III devices to the applicable conformity assessment procedures and notified-body involvement.
Article 61 and Annex XIV require clinical evaluation, sufficient clinical evidence, justified evidence level, lifecycle updates, and documentation in the technical file.
"Software intended to provide information"
More quoted passages
"software"
"Conformity assessment procedures"
"clinical data providing sufficient clinical evidence"
June 2025 guidance used for medical device software qualification, modular intended purpose, non-qualifying functions, software location, software driving or influencing a device, and Rule 11 interpretation.
June 2025 revision explaining medical device software qualification, intended-purpose and module scope, non-qualifying functions, software location, risk as a non-qualification criterion, and software that drives or influences a device.
Guidance used for software change-control evidence, including architecture, algorithm, closed-loop, interoperability, diagnostic or therapeutic feature, and medical-data presentation changes.
Transitional guidance for legacy devices under MDR Article 120; its software change chart identifies changes that may be significant for continued use of that transition.
April 2026 guidance used for Annex VIII classification context, active-device cross-checks, and the warning that software should not be reviewed only under Rule 11.
April 2026 classification guidance noting that software is an active device and should not be assessed only under Rule 11.
"Software is also an active device"
More quoted passages
"Software should be reviewed not only in the context of Rule 11"