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When is Software a Medical Device?

Short answer

As soon as the manufacturer designates it for a medical purpose – diagnosis, monitoring, treatment, or alleviation of diseases. Rule 11 of the MDR classifies software that provides decisions for diagnostic or therapeutic purposes at least as Class IIa. Pure data storage, archiving, or communication without its own assessment does not fall under this.

It’s About the Intended Use

It is not the function that determines this, but what the manufacturer specifies as the use. The same computing logic can be a medical device in one case and not in another – depending on what it is offered for.

This also means: One does not accidentally become a medical device manufacturer, but certainly through one’s own advertising. Anyone promoting administrative software as being able to detect anomalies in findings has changed the intended use.

Rule 11 of the MDR

There is a specific classification rule for software:

Effect of Decision Class
Death or irreversible deterioration possible III
Severe deterioration or surgical intervention IIb
Other decisions regarding diagnosis or therapy IIa
Monitoring physiological processes with critical parameters IIb
Other monitoring IIa
No medical purpose not a medical device

Practically speaking, software that medically co-decides almost always ends up in at least Class IIa – and thus in a procedure with a notified body.

What Does Not Fall Under This

  • Appointment management and billing
  • Pure storage and archiving without assessment
  • Communication between healthcare providers
  • Software that only displays values without interpreting them

Advice for Practice

The classification should be at the beginning of a project, not at the end. A subsequent reclassification usually means that the development must be largely re-documented.

This text does not replace regulatory advice.

Key facts

Trigger
The manufacturer's intended use
Rule 11 MDR
Decision-supporting software usually from Class IIa
Not Covered
Administration, archiving, communication without assessment

Sources

All external claims are backed by traceable sources.
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