Skip to main content Skip to search Skip to main navigation

EU: Dual Application of MDR/IVDR and AI Act for AI-Based Medical Devices

The Medical Device Coordination Group (MDCG), in collaboration with the Artificial Intelligence Board (AIB), has released MDCG 2025-6, a joint guidance document detailing how the Medical Device Regulation (MDR), In Vitro Diagnostic Regulation (IVDR), and the new Artificial Intelligence Act (AIA) must be applied in tandem to Medical Device Artificial Intelligence (MDAI) systems.

The document establishes that a MDAI qualifies as a “high-risk AI system” under Article 6(1) AIA if both of the following conditions are met:

  1. The AI system is either a safety component of the device or the AI system is the medical device itself, and

  2. The device is subject to third-party conformity assessment by a Notified Body under MDR or IVDR.

Crucially, it is the MDR/IVDR classification that determines whether the AIA applies—not the other way around. Under Article 8(2) AIA, manufacturers may embed AIA-mandated testing, monitoring, and documentation into existing MDR/IVDR processes (e.g. quality management systems, technical documentation, post-market surveillance), as long as full compliance with both regulatory frameworks is ensured.

The guidance provides clarity on:

  • the distinction between “deployer” (AIA) and “user” (MDR/IVDR),

  • data governance with attention to bias mitigation and data quality,

  • requirements for human oversight, and

  • obligations for transparency and explainability of AI behavior.

Structured as an FAQ, MDCG 2025-6 is an evolving document intended to support consistent and efficient implementation. For MDAI manufacturers, it is a critical step in preparing for full compliance with the AIA from August 2, 2027 onward.


Source:

EC: Latest updates - MDCG 2025-6 - FAQ on Interplay between the Medical Devices Regulation & In vitro Diagnostic Medical Devices Regulation and the Artificial Intelligence Act (June 2025)


Meet the GMP Compliance Adviser

The GMP Compliance Adviser is the world's largest knowledge portal for quality management in the pharma business. 

The demo access is non-binding and ends automatically.

Test it now for free

You may also be interested in the following articles:

ICH: Updated Q9(R1) Briefing Pack

ICH: Updated Q9(R1) Briefing Pack

The ICH has fully revised the Q9(R1) Briefing Pack (March/April 2026) to align with the updated ICH Q9 guideline.
Read more
EMA: New Plans for the EU GMP Guide

EMA: New Plans for the EU GMP Guide

EMA published the GMDP Inspectors Working Group’s new 2026-2028 work plan and its 2025 annual report.
Read more
EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA: Pharmaceutical Quality System (PQS) Effectiveness Pilot Project

EMA launched a pilot under which EEA GMP inspectors will assess how sites demonstrate the effectiveness of their pharmaceutical quality system for risk-based change management, and whether the EEA GMP certificate could serve as the main evidence of this effectiveness.
Read more
EMA: Updated Guideline on Active Substance Chemistry

EMA: Updated Guideline on Active Substance Chemistry

The EMA has updated guidance on the information required for the manufacture and control of active substances used in medicinal products, with a 1 September 2026 date of application.
Read more
EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA: Q&A on the Implementation of 3DP Technology for Solid Oral Dosage Forms

EMA added a new GMP/Q&A section on its website and published a dedicated Q&A document on 3D printing (3DP) for solid oral dosage forms.
Read more
Microbiological Monitoring – Sources of Contamination

Microbiological Monitoring – Sources of Contamination

All pharmaceutical dosage forms must be manufactured under controlled microbiological conditions. This requires microbial monitoring. This applies not only to sterile manufacturing, but also to facilities that manufacture non-sterile products.
Read more
Previous
Next