The device regulatory map at a glance

Medical device rules follow the product lifecycle. The table maps each stage to the main source in each region and the global standards behind them. Each link goes to a detailed article.

Lifecycle stageJapanUnited StatesEuropean UnionGlobal
Market access lawPMD ActFD&C Act and 21 CFRMDR 2017/745IMDRF
Quality management systemQMS Ordinance (MO169)QMSR, 21 CFR 820MDR Article 10 and harmonised ISO 13485ISO 13485
Risk managementQMS OrdinanceQMSR (risk management now explicit)MDR Annex IISO 14971
Software and electrical safetyPMDA guidanceFDA guidanceMDCG guidanceIEC 62304, IEC 60601
Interpretation and guidancePMDA guidelinesFDA guidanceMDCG guidanceIMDRF documents
Registration and databasese-Gov Law Search (law text)FDA databasesEUDAMED—
Inspection and enforcementPMDA and prefectural inspectionsForm 483, warning lettersNotified bodies and competent authorities—

What changed for device makers in 2025 and 2026

DateChangeRegion
16 Dec 2025Commission proposes targeted MDR/IVDR simplification (not yet law; adoption expected around Q2 2027)EU
2 Feb 2026QMSR takes effect; ISO 13485:2016 incorporated by reference; QSIT retiredUS
28 May 2026Four EUDAMED modules become mandatoryEU
May 2026Further stage of the 2025 PMD Act amendment takes effectJapan
2026Many new MDCG documents on UDI, EUDAMED, and EMDNEU
Sep 2026IEC 62304 edition 2 expected date moves to 26 October 2028Global
31 Dec 2027MDR legacy deadline for class III and class IIb implantable devicesEU
31 Dec 2028MDR legacy deadline for other class IIb, IIa, Im, and Is devicesEU

The big theme: ISO 13485 is now the common QMS baseline in all three regions. Japan aligned its QMS Ordinance in 2021, the EU relies on the harmonised standard, and the US joined in February 2026. That makes cross-region QMS work easier, but it also means more teams want ISO text in their AI tools, which ISO’s licence does not allow without permission.

AI use terms for device sources

SourceAI and RAG use
FDA regulations and guidancePublic domain unless noted; tag draft vs final
eCFRReusable; not the official legal edition, so record the “as of” date
MDR and MDCGCC BY 4.0 with attribution; only the Official Journal is authentic; keep MDCG separate from the law
EUDAMEDCheck required: operator and personal data
PMDA guidelinesPDL1.0, but crawling and bulk download prohibited
IMDRFInternal, non-commercial use only without permission
ISO 13485, ISO 14971No AI or ML use without a separate licence, including prompting and querying
IEC 62304, IEC 60601No use in public or private AI tools without IEC’s express permission

Building a device knowledge base

  1. Make QMSR, MDR, and the QMS Ordinance the core, each with its version date.
  2. Map your procedures to ISO 13485 clause numbers without loading ISO text.
  3. Archive pre-February 2026 Part 820 (QSR) text and label it superseded.
  4. Keep MDCG and FDA guidance as a separate, nonbinding layer.
  5. Store the 2025 EU proposal as “proposed,” not current law.
  6. Track deadlines: end 2027 and end 2028 MDR legacy dates, EUDAMED modules still to come, IEC 62304 edition 2.

How AskDona helps

AskDona checks your quality manual, technical files, and software lifecycle records against QMSR, MDR, and the QMS Ordinance in one pass, citing each requirement to its region and version. It works on your own documents, so licensed ISO and IEC text stays out unless your licence allows it.

Run a sample three-region device QMS check

AskDona shows the evidence; your regulatory team decides.

Editor’s note. This article is general information, not legal advice. Status and terms summarize the detailed articles linked above, each checked against official or primary pages by October 26, 2026.

FAQ

Is ISO 13485 now required in the US? Yes, in practice. The QMSR, effective 2 February 2026, incorporates ISO 13485:2016 by reference.

When must legacy devices be MDR certified? By 31 December 2027 for class III and IIb implantables, and 31 December 2028 for other classes, if conditions are met.

Can I put ISO 13485 or IEC 62304 into my AI tool? Not without permission. Both ISO and IEC restrict AI use in their licence terms.

Which EUDAMED modules are mandatory? Actor registration, UDI and device registration, notified bodies and certificates, and market surveillance, since 28 May 2026.

References

All pages opened and checked by October 26, 2026. Each linked article lists its own primary sources.

SourceWhat it supports
FDA: QMSRQMSR effective 2 Feb 2026; ISO 13485 by reference
Regulation (EU) 2023/607MDR legacy deadlines
Baker McKenzie: EU 2025 MDR/IVDR proposalProposal date and expected adoption
European Commission: EUDAMED overviewMandatory modules
European Commission: MDCG guidance2026 MDCG documents; not legally binding
ISO: Licence agreementAI and ML restrictions
IEC Webstore: Terms and conditionsAI restrictions
QuickBird Medical: IEC 62304 edition 2 delayedExpected date 26 Oct 2028
IMDRF Document Implementation Report 2026IMDRF terms