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MDCG 2019-11 Rev. 1: Important Updates for Medical Device Software (MDSW) Manufacturers

 

The European Commission has published Revision 1 of the MDCG Guideline 2019-11 and introduced important clarifications for medical device software under the MDR. The most important new features include:

  • Clarification of the scope: Expanded definitions and delimitations for medical device software (MDSW)
  • Emphasis on precise formulation of the intended purpose: A clear and unambiguous intended purpose is crucial for correct classification and avoiding compliance issues.
  • Clarification of Rule 11: New guidance specifically for disease prevention software
  • Expanded examples: New software use cases and clarifications regarding Annex XVI devices (devices without a medical purpose).
  • Detailed guidance on the assessment of modules: Explanations on how to consider individual software functions or components in the classification process.
  • Reference to the European Health Data Space: Annex I now includes information on the relevance of interoperability and data security, particularly in the context of electronic health records (EHRs).
  • Addition of an example for Class I MDSW: Annex IV includes a new practical example to support implementation by manufacturers.

Revision 1 aims to adapt the guideline to the regulatory landscape and the practical challenges of MDSW approval.