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CE-marking pathway for software-centered medical technologies under MDR

The CE-marking process for medical software begins with determining whether the software qualifies as a medical device and assigning the applicable risk class. The resulting classification defines the conformity assessment route, the level of Notified Body involvement, and the scope of technical documentation. For software products, the process also requires alignment between MDR requirements, IEC 62304 lifecycle documentation, ISO 14971 risk management, clinical evaluation, cybersecurity, usability engineering, quality management, registration, and post-market activities. The diagram below shows the main regulatory steps and class-dependent pathways.

Determine the CLASSIFICATION of your device using Annex VIII of the Medical Device Regulation Class I Non-sterile Non-measuring Not reusable surgical Class I Sterile Measuring Reusable surgical Class IIa Class IIb Class III Implement QUALITY MANAGEMENT SYSTEM (QMS) in accordance with MDR. Most companies apply ISO 13485 standard to achieve QMS compliance. Prepare TECHNICAL DOCUMENTATION which provides detailed information demonstrating compliance with the Medical Devices Regulation EC 2017/745 Appoint an AUTHORISED REPRESENTATIVE (EC REP) located in Europe and qualified to handle regulatory issues. Place EC REP name and address on packaging Register the manufacturer and the medical device in the EUDAMED database. As a result you will get the unique device identifier (UDI). Your QMS and Technical File or DESIGN DOSSIER must be audited by a Notified Body. A CE Certificate for your device will be issued upon successful completion of the Notified Body audit. Prepare a DECLARATION OF CONFORMITY, a legally binding document prepared by the manufacturer stating that the device is in compliance with the applicable Regulation. You may now affix the CE Marking.
01

Medical device qualification and classification

The European regulatory pathway begins with determining whether the product qualifies as a medical device and identifying the applicable classification under Annex VIII of the MDR. For medical device software, AI-enabled healthcare solutions, digital healthcare platforms, and software-driven physical devices, classification depends on the intended purpose, the role of the software in clinical decision-making, the significance of the information it provides, and the potential consequences of an incorrect output. A classification assigned in another jurisdiction may not correspond to the classification applicable in the European Union.

02

Technical documentation

Technical documentation provides the structured evidence required to demonstrate compliance with the MDR. For software-centered medical technologies, it typically integrates device description, intended purpose, software architecture, lifecycle documentation, risk management, cybersecurity, usability engineering, verification and validation, clinical evaluation, and post-market planning. For software-driven physical devices, the documentation must also address the relevant hardware, manufacturing, and product-specific safety and performance requirements.

03

Quality management system compliance

A Quality Management System provides the organizational framework for controlling the product throughout its lifecycle. For software, AI-enabled systems, and connected medical technologies, the QMS should cover software development, configuration and change control, supplier management, verification and validation, cybersecurity maintenance, release management, incident handling, post-market surveillance, and corrective and preventive actions. ISO 13485 is commonly used to structure these processes.

04

EU Authorised Representative

Manufacturers established outside the European Union must appoint an EU Authorised Representative. The representative acts as the formal regulatory contact in the EU and performs the responsibilities assigned under the MDR, including verification of selected compliance documentation, cooperation with competent authorities, and support in relation to registration, vigilance, and post-market obligations.

05

Notified Body assessment and certification support

Medical device software and software-driven products classified above Class I generally require conformity assessment by a Notified Body. The assessment may cover the Quality Management System, technical documentation, software lifecycle processes, risk management, cybersecurity, clinical evidence, and post-market activities. We support manufacturers in preparing for the assessment, reviewing documentation for consistency and completeness, responding to Notified Body questions, and maintaining compliance after certification.

Build regulatory compliance into your software, AI, and medical technology lifecycle from the outset. We are here to help you structure the required processes, documentation, and evidence.

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Useful information

CE-Certificate vs. EC-Certificate

Basic UDI-DI (bUDI)

EUDAMED registration - a brief guide

Authorised Representative Mandate

GSPR – General Safety and Performance Requirements

How to obtain CE marking for medical software under the EU MDR or IVDR?

Technical documentation for Medical Device Software in the EU

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Send us an email:
info@mdrc-services.com

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Solutions

EU Authorised Representative (EC REP)

EU PRRC

Technical documentation

Risk management

Clinical evaluation

Notified Bodies

Quality management system

Post-market surveillance

Resources

Medical Device Regulation (MDR) - basics

CE-marking process for medical devices

CE-marking process for in vitro diagnostic medical devices

PRRC under MDR or IVDR

UDI infographic

EUDAMED registration step by step instruction

ISO 14155:2020 structure and content

MDR-compliant technical file

Checklists

MDR technical documentation checklist

IVDR technical documentation checklist

Technical documentation checklist for medical device software (MDSW)

MDR-compliant quality system documentation checklist

Clinical Evaluation Plan checklist

Clinical Evaluation Report checklist

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Articles

CE-Certificate vs. EC-Certificate

Basic UDI-DI (bUDI)

EUDAMED registration - a brief guide

Authorised Representative Mandate

GSPR – General Safety and Performance Requirements

More articles >>

Devices

General medical devices and equipment

In vitro diagnostics (IVD)

Medical software

Cookie Policy

We only use essential cookies that enable core functionality and proper operation of the website. These cookies do not store any personally identifiable data. By continuing to use this website, you consent to the use of the essential cookies. You may disable these cookies by changing your browser settings, but this may affect how the website functions.
We do not use our own or third-party analytical, preferences, statistics, marketing, functional, advertisement, performance or any other non-essential cookies.