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Medical device organizations often work across several quality-management frameworks. The challenge is determining which requirements apply, how they overlap, and what additional controls are needed for each product, activity, and target market.
Elexes provides QMS standards and compliance services for organizations establishing, implementing, assessing, remediating, or maintaining a quality management system. Our support covers medical device manufacturers, specification developers, contract manufacturers, suppliers, importers, distributors, and other organizations with quality-system responsibilities.
Whether you are building your first QMS, preparing for certification, transitioning to FDA QMSR, planning an MDSAP audit, or integrating ISO 9001 with medical-device controls, the starting point is the same: clearly define the frameworks and regulatory obligations that apply to your organization.
ISO 13485, FDA QMSR, MDSAP, and ISO 9001 are related, but they do not serve the same purpose.
Some are standards against which an organization may be certified. Others are regulatory requirements or audit programs. One organization may need to address several frameworks simultaneously, together with country-specific requirements that sit outside them.
The applicable combination depends on:
⦿ The organization’s regulatory role
⦿ The activities it performs
⦿ The medical devices and technologies involved
⦿ Design and manufacturing responsibilities
⦿ Outsourced processes
⦿ Target markets
⦿ Existing certifications and regulatory approvals
⦿ Product risk and lifecycle stage
⦿ Customer and contractual requirements
ISO certification alone should not be treated as proof that every regulatory requirement has been met in every market.
ISO 13485:2016 is the internationally recognized quality-management-system standard developed specifically for the medical-device sector. ISO confirmed the 2016 edition as current following its 2025 review.
It may apply to legal manufacturers and organizations involved in design, development, production, storage, distribution, installation, servicing, and related activities. Suppliers and external parties supporting medical device organizations may also implement the standard where appropriate.
In a general way, ISO 13485 QMS covers:
⦿ Scope, processes and documents of the QMS
⦿ Management responsibility and control
⦿ Resources, infrastructure and competence
⦿ Risk management controls
⦿ Requirements of the customer and regulations
⦿ Design and development of the product
⦿ Controls of suppliers and outsourced processes
⦿ Production and service operations
⦿ Product identification and traceability
⦿ Validations of applicable processes
⦿ Feedback and complaints
⦿ Nonconformities
⦿ Corrective and preventive actions
⦿ Internal audits and management reviews
⦿ Monitoring and measurement
The exact controls that apply depend on the organization’s role and activities. For example, a legal manufacturer with design responsibility will have a different operational scope from a component supplier that does not design or release finished devices.
Certification can demonstrate that an organization’s QMS has been independently assessed against ISO 13485. It does not, by itself, establish compliance with every device regulation, registration requirement, reporting obligation, or market-specific control.
The FDA Quality Management System Regulation is the current US device QMS framework in 21 CFR Part 820. The amended regulation became effective on February 2, 2026.
The QMSR incorporates ISO 13485:2016 by reference and adds FDA-specific definitions, requirements, and connections to other applicable provisions of US medical device law.
FDA QMSR compliance is a legal obligation for manufacturers and other entities within its scope. It is not a separate ISO certification program, and an ISO 13485 certificate does not prevent FDA from conducting an inspection or taking regulatory action.
A manufacturer subject to Part 820 must document a QMS that complies with the applicable incorporated ISO 13485 requirements and applicable FDA provisions.
Depending on the product and activities, the broader US compliance framework may also involve requirements covering:
⦿ Medical Device Reporting
⦿ Corrections and Removals
⦿ Unique Device Identification
⦿ Device Tracking
⦿ Registration & Listing
⦿ Labeling
⦿ Premarket Requirements
⦿ Adverse Event and Complaint Reports
⦿ FDA Inspection and Record Availability
Under the current regulation, design-and-development requirements apply to Class II and Class III devices and specified Class I devices identified in Part 820. Applicability therefore needs to be assessed against the actual device and operations rather than assumed from certification status.
The Medical Device Single Audit Program allows a recognized Auditing Organization to conduct a single regulatory audit addressing the requirements of participating regulatory authorities.
The five MDSAP Regulatory Authority Council members are:
⦿ Australia’s Therapeutic Goods Administration
⦿ Brazil’s ANVISA
⦿ Health Canada
⦿ Japan’s MHLW and PMDA
⦿ The US Food and Drug Administration
The program is based on ISO 13485 and incorporates participating regulatory authorities’ applicable requirements. Its audit approach evaluates QMS processes and the relationships among management, measurement and improvement, design and development, production and service controls, purchasing, and other supporting activities.
MDSAP can be mandatory, accepted, or used in other ways according to the location and the regulation strategy of the manufacturer. It is important to check the relevance of MDSAP on a case-by-case basis.
A manufacturer preparing for MDSAP should consider:
⦿ The sites and activities included in the audit scope
⦿ Applicable country-specific requirements
⦿ Device registrations and licences
⦿ Outsourced activities
⦿ Previous audit findings
⦿ Complaint and post-market data
⦿ CAPA efficacy
⦿ Supplier management
⦿ Design and manufacture documentation
⦿ Availability of records at various sites
The MDSAP does not eliminate the requirement for meeting other product registration, vigilance, license, or market-specific requirements.
ISO 9001:2026 is the international quality management system standard tailored to the medical devices industry. The international organization reaffirmed the 2016 version as current after the 2025 review.
The standard applies to manufacturers and organizations that undertake activities such as design, development, manufacturing, packaging, installation, servicing, distribution, storage, and other relevant functions of medical device manufacturers. External suppliers and organizations supplying medical devices may also adopt the standard where appropriate.
The 2026 edition places increased emphasis on quality culture and leadership, treats risks and opportunities separately, and improves alignment with other ISO management-system standards.
However, ISO 9001 is not a medical-device-specific regulatory framework. It does not replace ISO 13485, FDA QMSR, MDSAP requirements, or applicable medical-device legislation.
Some organizations have an integrated QMS that includes both standards. This is appropriate for organizations that:
⦿ Supplies medical-device and non-medical-device sectors
⦿ Has customer contracts requiring ISO 9001
⦿ Operates a broader corporate QMS
⦿ Needs medical-device-specific controls within a larger quality system
The company should identify common processes without losing controls specific to the medical device sector, regulation, reporting, risk management, traceability, validation, complaints, product documentation, and marketing.
Firms certified to ISO 9001:2015 should coordinate their transition expectations with the time frame of their certification body.
Yes. It is possible to have a QMS that is certified under ISO 13485, FDA QMSR for the United States, MDSAP audit for participating regions, and ISO 9001 for more comprehensive integrated management systems.
The solution should not be four disconnected systems.
A well-designed QMS can use shared processes for document control, training, management review, internal audits, CAPA, supplier management and change control while clearly identifying where additional regulatory or framework-specific requirements apply.
A practical applicability matrix should show:
⦿ Which requirement is applicable
⦿ Why it is applicable
⦿ Which process does it apply to
⦿ Who has control over the process
⦿ Evidence of application
⦿ The relevant site or product
⦿ Monitoring of changes
⦿ Possible audits or inspections
This approach makes overlaps visible while reducing contradictory procedures and duplicated records.
We assess the organization’s role, activities, devices, sites, markets, outsourced processes, existing approvals and certifications. Current procedures and records are then compared with the applicable framework and regulatory requirements.
The assessment will distinguish among:
In response to findings from audits, findings from inspections, recurring quality occurrences, or poor controls, Elexes could help address:
For new or expanding organizations, support may include QMS scope definition, process architecture, responsibility mapping, document hierarchy, procedure development, training, implementation planning, and evidence generation.
The objective is to create a system that reflects actual operations rather than a generic library of procedures.
Elexes can support the development or review of policies, procedures, work instructions, forms, templates and records. Documentation is aligned with process ownership, approval authority, regulatory responsibilities and the organization’s operating model.
If there is more than one framework, the requirements could be documented into an integrated document structure.
Personnel need to understand both the documented process and their responsibilities within it. Training may cover framework awareness, role-specific procedures, implementation expectations, required records, escalation routes and audit preparation.
Training completion alone is not treated as evidence that a process is effective. Implementation should also be evaluated through records, interviews, monitoring and internal audits.
Readiness activities can include focused document review, record sampling, internal audits, mock assessments, interview preparation, evidence organization, finding closure and process-owner support.
Readiness cannot guarantee a particular certification, audit, or inspection outcome. It helps identify weaknesses before the external assessment and confirms whether implemented controls can be demonstrated through objective evidence.
A QMS should be proportionate to the organization, but every applicable requirement still needs to be addressed.
Before developing new procedures or preparing for an audit, establish:
⦿ Your organization’s regulated role
⦿ The products and technologies in scope
⦿ The markets you intend to enter or maintain
⦿ The activities performed at each site
⦿ The responsibilities assigned to external parties
⦿ The applicable standards and regulations
⦿ The evidence already available
⦿ The gaps that could affect certification or compliance
Elexes can help convert this information into a prioritized QMS compliance roadmap covering assessment, implementation, remediation, training, and readiness.
Not universally. Its relevance depends on the organization’s role, target markets, conformity-assessment route, customer requirements and regulatory obligations. Some markets or commercial relationships may make certification necessary in practice. Applicability should be evaluated for the specific organization and device portfolio.
No. ISO 13485 certification and FDA QMSR compliance are different. The QMSR incorporates ISO 13485:2016 by reference but includes FDA specific provisions and connections to other US regulations. FDA retains its inspection and enforcement authority.
No. MDSAP is an audit program based on ISO 13485 that also evaluates applicable requirements of participating regulatory authorities. It does not replace the underlying standard or other market-specific obligations.
ISO 9001 is a general QMS standard. It does not replace medical-device-specific QMS or regulatory requirements. An organization may use both standards within an integrated system when appropriate.
Yes. A common QMS can address shared processes across markets, but country-specific controls must still be identified and implemented. These may include registrations, reporting, recordkeeping, traceability, licensing, local representation and post-market obligations.
It should review applicability, documentation, implementation and objective evidence. This includes whether processes are assigned, followed, monitored and effective mnot merely whether procedures exist.
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