FDA QMSR 2026 Readiness Checklist (ISO 13485 Alignment)

Nov 21, 2025

FDA’s Quality Management System Regulation (QMSR) will align 21 CFR 820 to ISO 13485. Use this checklist to prep your QMS ahead of the expected 2026 go-live.

1) Gap assess ISO 13485 vs. current QSR controls

  • Map procedures (design control, purchasing, production, servicing) to ISO 13485 clauses.
  • Confirm risk-based approaches in SOPs and records.
  • Align document control, training, and record retention to ISO 13485 language.

2) Risk management integration

  • Trace design inputs/outputs to ISO 14971 risk controls.
  • Ensure risk files feed verification/validation, labeling, and CAPA.
  • Show risk-based supplier control and change control decisions.

3) Software/CSV and SaMD

  • Clarify software lifecycle approach (IEC 62304/820.30) and validation of QMS software.
  • Ensure cybersecurity and data integrity are captured in design and production controls.

4) Supplier and purchasing controls

  • Re-qualify critical suppliers with ISO 13485-aligned criteria.
  • Refresh quality agreements and monitor performance indicators.

5) CAPA and post-market

  • Risk-prioritized CAPA with effectiveness checks.
  • Complaint handling/medical device reporting alignment and vigilance signaling.
  • Management review inputs reflecting risk and post-market data.

How MedReg AI helps

  • Run a QMSR gap check against ISO 13485 language to highlight weak SOPs/records.
  • Trace risk controls to design, labeling, and supplier files to evidence integration.
  • Produce an executive gap summary for leadership before FDA inspections.

Start by updating your gap list, then assign owners and timelines. To trial MedReg AI, see /pricing or reach us at /contact.

MedReg AI Team

MedReg AI Team

FDA QMSR 2026 Readiness Checklist (ISO 13485 Alignment) | Blog