EU MDR Technical Documentation Checklist (Annex II & III)

Sep 12, 2025

EU MDR technical documentation must satisfy Annex II (content) and Annex III (post-market). Use this checklist to validate completeness before engaging a Notified Body.

1) Device description and specifications

  • Intended purpose, indications, contraindications, user profile, and environments.
  • Classification rationale (Rule-based) and accessories/variants list.
  • UDI strategy and labeling symbols aligned to EN ISO 15223-1.
  • GSPR mapping table with evidence references.

2) Design and manufacturing information

  • Design outputs, drawings, BOM, critical suppliers, and manufacturing flow.
  • Software architecture, cybersecurity controls, SOUP list, and configuration management.
  • Verification reports tied to design inputs; change control records for iterations.

3) Benefit-risk and risk management file

  • ISO 14971 risk management plan, hazard analysis, and residual risk evaluation.
  • Risk control measures with verification/validation proof.
  • Usability and human factors evidence aligned to IEC 62366.

4) Product verification and validation

  • Bench/functional testing with acceptance criteria and summary reports.
  • Biocompatibility and sterilization (if applicable) or justification of non-applicability.
  • Electrical safety/EMC (IEC 60601 series as applicable).
  • Software verification/validation and cybersecurity tests.
  • Packaging/transportation testing and shelf-life studies.

5) Clinical evaluation (CER)

  • Clinical evaluation plan, PMCF plan (if needed), and state-of-the-art analysis.
  • Clinical data appraisal, equivalence justification, and benefit-risk conclusions.
  • Summary of safety and clinical performance (SSCP) where required.

6) PMS and PMCF (Annex III)

  • PMS plan with data sources, indicators, vigilance, trend reporting.
  • PMCF activities, protocols, and triggers for updates.
  • CAPA linkage and management review inputs.

7) Declaration of conformity and QMS

  • EU Declaration of Conformity with references to applied harmonized standards.
  • QMS alignment with ISO 13485 and MDR Article 10 requirements.
  • Economic operator roles and agreements (manufacturer, importer, distributor).

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MedReg AI Team

MedReg AI Team