ISO 13485:2016 certified · Startup India (DPIIT) recognised · NVIDIA Inception program member +91 44 4690 0555info@medoqi.tech
Home/Regulatory Affairs/MDR & IVDR transition
European Union

EU MDR & IVDR Transition

Legacy devices placed on the market under MDD, AIMDD or IVDD certificates must move to the MDR or IVDR within extended, conditional transition periods. We run the transition as a governed programme, from portfolio decisions to certification.

Regulation (EU) 2023/607Regulation (EU) 2024/1860MDR Art. 120IVDR Art. 110
Who this is for

Three situations we see most

Medical devices

Legacy MDD and AIMDD devices

Devices relying on legacy certificates and the extended MDR transition periods, with Notified Body agreements to honour.

IVDs

IVDs entering Notified Body review

Many devices self-certified under the IVDD now need a Notified Body under the IVDR, often for the first time.

Portfolio

Portfolio rationalisation

Deciding which products to transition, combine or withdraw, based on revenue, evidence gaps and certification cost.

Transition periods

Extended deadlines, with conditions

Extended periods apply only where conditions are met, including a QMS in place and a Notified Body application and written agreement by set dates. Several of those dates have passed, so eligibility must be confirmed device by device.

  • Since 10 January 2025, manufacturers must also give advance notice of supply interruptions that could cause serious harm (Article 10a, MDR and IVDR).
RegulationDevicesTransition ends
MDRClass III and Class IIb implantable devices, with listed exceptions31 Dec 2027
MDROther Class IIb, Class IIa, and Class I devices needing a Notified Body31 Dec 2028
IVDRClass D31 Dec 2027
IVDRClass C31 Dec 2028
IVDRClass B and sterile Class A31 Dec 2029
Programme approach

Moving a whole portfolio, not just one file

Two parallel streams: the quality system first, then each product file under the updated procedures.

  1. Programme01

    Programme set-up

    Steering committee, charter, core team, plans, communication and status reporting.

  2. Portfolio02

    Portfolio assessment

    Review every product for impact, classification, grouping and rationalisation.

  3. QMS stream03

    QMS gap assessment

    Assess the QMS against MDR or IVDR, prioritise gaps by risk and complexity, assign process owners.

  4. QMS stream04

    QMS update

    Revise procedures and templates so all remediation follows the new process.

  5. Product stream05

    Product gap assessment

    Assess each technical file against the checklist and prioritise gaps, such as testing or clinical data generation.

  6. Product stream06

    Product remediation

    Close the gaps using the updated procedures, templates and current state of the art.

  7. Certification07

    Submission preparation

    Compile the updated documentation into the technical documentation template for review.

  8. Certification08

    Conformity assessment

    Notified Body liaison, query responses and certification under the new regulation.

Where GapSmart AI™ will fit. GapSmart AI, now in testing and validation, is designed to run the first-pass gap screen of each technical file against MDR or IVDR requirements for large portfolios. Our specialists validate and prioritise every finding before remediation starts.
Talk to our experts

Discuss your device, market or audit with a specialist

Share the device, its class and your target markets. A senior specialist will come back with the likely pathway, the evidence gaps we see and a practical plan.

Talk to our experts → Request an AI pilot sales@medoqi.tech · +91 44 4690 0555