The future of in vitro diagnostics

The future of in vitro diagnostics is being written at the intersection of tighter regulation, workforce pressure, and data‑driven innovation. Under the EU In Vitro Diagnostic Regulation (IVDR), evidence expectations and lifecycle obligations have risen sharply, changing how products are designed, validated, and maintained in the market. For manufacturers, success now depends on pairing scientific advances with stronger clinical evidence strategies, interoperable data flows, and operational resilience across supply, quality, and post‑market systems.

Demand is rising while systems are stretched

Backlogs from the pandemic have converged with long‑standing workforce shortages, particularly in diagnostic specialties, delaying access and lengthening diagnostic pathways. The OECD’s Health at a Glance: Europe 2024 highlights these shortages as a structural risk to access, quality, and system resilience—evidence that the pressure to do more with fewer people is not easing soon. For diagnostics leaders, that reality elevates the value case for automation, near‑patient testing, and real‑world evidence that proves earlier, faster decisions.

Market momentum is real—if evidence and access align

IVDs remain a cornerstone of Europe’s medtech economy and the largest segment globally by sector share, signaling robust demand for better, earlier diagnostics. But translating that momentum into market access requires credible performance evaluation, clear intended‑purpose claims, and a plan for post‑market performance follow‑up that stands up to Notified Body scrutiny. (MedTech Europe DataHub – Market). 

IVDR is raising the bar—and capacity is still normalizing

IVDR’s higher evidence threshold is now a constant, but Notified Body (NB) capacity and throughput continue to shape time‑to‑market. The European Commission’s latest Notified Bodies Survey shows progress on designations and certifications under MDR/IVDR while acknowledging persistent bottlenecks—practical context for planning dossier quality, NB engagement, and transition timelines. Manufacturers that front‑load clinical evidence planning and close gaps against GSPR, PER, and PMPF requirements are better positioned to move through review without costly rework. 

What the next decade looks like for IVD innovators

Expect faster iteration cycles powered by cloud connectivity and AI‑assisted analytics, paired with stronger governance of data provenance, cybersecurity, and change control. Procurement and HTA bodies will demand interoperable outputs that feed clinical systems and population analytics. In practice, this means designing for the 4P future—predictive, preventive, personalized, and participatory—while proving clinical performance and patient‑management claims under IVDR. Aligning technical files, labeling, and performance evaluation with clinical utility (not just analytical superiority) will increasingly differentiate winners.

What leaders should do now

Treat clinical evidence as a product pillar from day one—map intended purpose, target population, and clinical benefit to a coherent performance evaluation plan that integrates literature, device‑generated data, and targeted clinical performance studies. Build for integration and reuse of data across care settings to ease adoption and payer evaluation. Engage NBs early with complete, audit‑ready files. And make post‑market performance follow‑up a source of competitive insight, not a compliance afterthought.

How MDx CRO accelerates IVD market readiness

MDx CRO helps IVD manufacturers compress time‑to‑evidence and navigate IVDR with confidence—from regulatory strategy and technical documentation to clinical performance studies and post‑market performance follow‑up. We translate regulatory expectations into practical study designs and submission‑ready deliverables, then stay with you through NB interactions and lifecycle monitoring. Explore our IVD regulatory services and clinical research support, or contact us to scope a market‑access plan tailored to your portfolio.

Written by:
Carlos Galamba

Carlos Galamba

CEO

Senior regulatory leader and former BSI IVDR reviewer with deep experience in CE marking high-risk IVDs, companion diagnostics, and IVDR implementation.
Industry Insights & Regulatory Updates

MedTech Companies in Europe: Hubs, Opportunities, and What You Need to Know

Europe is one of the world’s most significant medical technology markets, and one of its most complex. With more than 38,000 MedTech companies operating across the continent, a rigorous regulatory framework under EU MDR and IVDR, and a network of world-class research and manufacturing clusters, it represents both a major opportunity and a substantial challenge for manufacturers, diagnostics companies, and pharma organisations looking to operate here.

This guide covers what the European MedTech landscape actually looks like: where the key hubs are, what kinds of companies operate here, and what any organisation, whether entering the EU market for the first time or scaling an existing presence, needs to understand about the environment they’re entering.

The Scale of Europe’s MedTech Industry

According to MedTech Europe, the sector directly employs over 930,000 people across the continent and generates annual revenues estimated at roughly €170 billion (2024). It is one of the largest life sciences industries in the world, second only to the United States in terms of market size.

A few figures that put the landscape in context:

  • 38,000+ companies: operating in medical devices, IVDs, and digital health
  • Over 90% are SMEs: the sector is dominated by small and mid-sized innovators, not large multinationals
  • Europe accounts for roughly 27% of global MedTech revenue
  • The EU is the world’s second-largest medical device market after the US
  • More than 2,000,000 medical technology products and services currently available in the European market

For US manufacturers, Asian diagnostics companies, and global pharma organisations, Europe is not a single market — it is a collection of national healthcare systems, procurement processes, and regulatory pathways that sit under a shared EU framework. Understanding where the industry is concentrated, and how it operates, is the starting point for any effective market strategy.

Europe’s Major MedTech Hubs

Germany: The Largest Market in Europe

Germany is the single largest MedTech market in Europe, accounting for roughly €40 billion in annual revenue and home to major global players including Siemens Healthineers, B. Braun, Dräger, and Karl Storz, alongside thousands of specialist mid-sized manufacturers (the Mittelstand).

Key clusters include:

  • Tuttlingen (Baden-Württemberg): The surgical instruments capital of the world. Over 400 MedTech companies operate within a 20km radius, manufacturing more than half of the world’s surgical instruments.
  • Munich: A hub for medical imaging, digital health, and life sciences, anchored by Siemens Healthineers and a growing startup ecosystem.
  • Hamburg and the Rhine-Ruhr region: Strong in diagnostics, laboratory technology, and healthcare IT.

Germany also hosts two of Europe’s most important MedTech trade events: MEDICA in Düsseldorf (the world’s largest medical trade fair) and COMPAMED, its companion event for medical technology suppliers.

For IVD and diagnostics companies, Germany is particularly significant, it is one of the largest markets for in vitro diagnostics globally and home to companies such as Roche Diagnostics and Qiagen.

The Netherlands: Diagnostics and Digital Health Innovation

The Netherlands punches well above its weight in MedTech. Philips Healthcare is headquartered in Amsterdam and Eindhoven, and the country has developed a strong ecosystem around medical imaging, point-of-care diagnostics, and health technology.

The Brainport Eindhoven region is one of Europe’s most productive technology clusters, with Philips and ASML as anchors and a dense network of high-tech suppliers and spin-offs. Dutch MedTech companies benefit from strong R&D infrastructure, close ties between university medical centres and industry, and an internationally oriented business environment.

The Netherlands is also a significant European gateway market, its logistics infrastructure (Rotterdam port, Schiphol Airport) and the presence of major European headquarters make it a preferred entry point for non-EU manufacturers registering their first EU presence.

France: A Major Market with Growing Innovation

France is the third-largest MedTech market in Europe, with a sizeable domestic industry and a healthcare system that is one of the continent’s largest public purchasers of medical technology.

Key companies include Stryker’s European operations, Guerbet, Servier Medical, and a growing cluster of digital health and AI-powered diagnostics startups concentrated around Paris, Lyon, and Grenoble. Lyon in particular has emerged as a strong hub for minimally invasive surgery and interventional cardiology, building on the presence of bioMérieux (a global diagnostics leader headquartered nearby in Marcy-l’Étoile).

France’s national innovation agency Bpifrance and the health innovation programmes under France 2030 have significantly increased investment in digital health and MedTech startups, making it an increasingly dynamic market for early-stage companies and international partners alike.

Spain: A Fast-Growing Hub with Iberian Reach

Spain is one of Europe’s most dynamic and fast-growing MedTech markets, with a strong concentration of companies in Barcelona, Madrid, and the Basque Country. The Spanish sector has historically been strong in orthopaedics, dental technology, and hospital equipment, but it is increasingly significant in IVDs, molecular diagnostics, and digital health.

Barcelona is home to a thriving life sciences ecosystem anchored by the Barcelona Health Hub, the proximity of world-class research institutions (IRB, CRG, ISGlobal), and a growing cluster of diagnostics and genomics companies. Madrid is the commercial and regulatory centre, with strong connectivity to Latin American markets — a route often used by global manufacturers to establish a dual EU/LATAM presence.

For companies targeting the Spanish and Portuguese-speaking world, Spain also serves as a strategic gateway to Latin America, with regulatory knowledge and commercial networks that extend to Brazil, Mexico, Colombia, and beyond.

A landmark development for the Spanish regulatory environment is Royal Decree 192/2023, which introduced specific requirements for clinical investigations with medical devices and IVDs in Spain, bringing national legislation into closer alignment with EU MDR and IVDR.

United Kingdom: Post-Brexit Reconfiguration

The UK remains one of Europe’s most important MedTech markets, even outside the EU. With a market value exceeding £10 billion, the UK is home to major global players (Smith+Nephew, Oxford Instruments, Consort Medical), a world-leading academic research base, and a concentration of MedTech companies around London, Cambridge, Oxford, and the M4 corridor.

The critical development for any manufacturer is the post-Brexit regulatory divergence. The UKCA mark (UK Conformity Assessed) is now required for devices placed on the Great Britain market, separate from the EU CE mark. While the UK has extended the period during which CE-marked devices can be sold in Great Britain, the timelines for full UKCA compliance are firm and require planning.

The MHRA (Medicines and Healthcare products Regulatory Agency) has been active in shaping post-Brexit regulatory guidance, and the UK has also signalled ambitions to develop faster, innovation-friendly pathways — including the ILAP (Innovative Licensing and Access Pathway) for combination products.

For manufacturers already CE-marked, the UK requires a separate regulatory strategy. For those entering from outside Europe, the question of CE + UKCA sequencing is an important early strategic decision.

Switzerland: Precision and High-Value Manufacturing

Switzerland is not an EU member but operates under a mutual recognition agreement for medical devices and is deeply integrated into the European MedTech ecosystem. It is home to some of the world’s most significant MedTech and diagnostics companies: Roche (Basel), Novartis (Basel), Straumann (dental), Ypsomed (drug delivery), and a dense cluster of precision manufacturing suppliers in the watch-making tradition that has transferred into surgical robotics, implants, and microfluidics.

Switzerland’s combination of engineering excellence, multilingual workforce, and proximity to major EU markets makes it a significant hub for high-value device development and manufacturing, and a frequent base for global companies establishing their European regulatory presence.

The Regulatory Landscape: What It Means in Practice

Understanding the MedTech industry in Europe is inseparable from understanding its regulatory framework. The introduction of EU MDR (2017/745) and EU IVDR (2017/746) represents the most significant overhaul of European medical device regulation in 25 years, and it has reshaped how companies of all sizes operate.

For manufacturers entering the EU market for the first time, the key requirements include:

  • CE marking through a conformity assessment route appropriate to the device’s risk classification
  • Technical documentation demonstrating safety and performance, including clinical evidence
  • Quality Management System (QMS) certified to ISO 13485
  • EUDAMED registration, the EU’s centralised database for devices, manufacturers, and clinical investigations, which becomes mandatory from May 2026
  • Notified Body involvement for Class IIa, IIb, III (MD) and Class B, C, D (IVD) devices
  • EU Authorised Representative (EU AR) for manufacturers based outside the EU

For IVD and diagnostics companies specifically, IVDR introduced a significant reclassification of products — the vast majority of IVDs that were previously self-certified under the old IVDD now require Notified Body review under IVDR, including companion diagnostics, oncology markers, and infectious disease assays. The transition timelines vary by device class and certification status.

For pharma companies developing companion diagnostics, the EU framework requires co-development alignment between the drug and its accompanying IVD, with specific submission pathways for Class D companion diagnostics (EMA consultation required).

Opportunities in the European MedTech Market

Despite, and in some ways because of, its regulatory complexity, Europe offers compelling opportunities for manufacturers and diagnostics companies with the right preparation.

Market access across 27 EU member states through a single CE mark remains one of the most powerful aspects of the European regulatory system. A device approved in Germany can be sold in France, Spain, Italy, Poland, and beyond without separate national approvals in most cases.

The SME ecosystem creates partnership opportunities. With over 90% of European MedTech companies being SMEs, there is a substantial market for contract research, regulatory outsourcing, clinical study support, and quality management services — particularly as regulatory demands increase under MDR and IVDR.

Growing demand in IVDs and molecular diagnostics is accelerating across Europe, driven by population ageing, oncology precision medicine, and the lessons of COVID-19 for diagnostic infrastructure. Countries including Spain, Portugal, Germany, and the Netherlands are investing significantly in laboratory infrastructure and point-of-care testing capacity.

The Spanish and Portuguese-speaking corridor (Spain, Portugal, and by extension Latin America) represents a particularly underexploited route for companies seeking both EU certification and access to a combined market of over 600 million people. Regulatory expertise that spans the EU and LATAM is rare and commercially valuable.

What Companies Operating in Europe Need to Get Right

Three things consistently determine whether a MedTech company navigates the European environment successfully:

1. Regulatory strategy from day one. The classification of a device under MDR or IVDR determines the entire development and approval pathway. Getting this wrong early, misclassifying a device, choosing the wrong conformity assessment route, or underestimating the clinical evidence requirements, creates delays that are expensive and difficult to recover from.

2. Clinical evidence that meets the standard. Both MDR and IVDR have raised the bar for clinical evidence significantly. For medical devices, clinical evaluation is an ongoing process, not a one-time submission. For IVDs, performance evaluation under ISO 20916 must be designed to satisfy both EU and, where applicable, FDA requirements.

3. A Notified Body relationship that works. With only a limited number of IVDR-designated Notified Bodies currently active, access to conformity assessment is a genuine constraint. Early engagement, well-prepared technical documentation, and experience managing the review process are not optional, they are the difference between a smooth approval and a two-year delay.

About MDx CRO

MDx CRO is a full-service MedTech CRO specialising in clinical research, regulatory affairs, and technical documentation for medical devices and IVDs. With offices in Barcelona, Madrid, Lisbon, and London, and a team operating across Europe, MDx supports manufacturers, diagnostics companies, and pharma organisations at every stage, from early regulatory strategy to Notified Body submission and post-market compliance.

Explore our services or get in touch to discuss your European regulatory and clinical strategy.

We partner with both large diagnostic leaders and agile SMEs to deliver compliant, high-quality, and market-ready solutions.

A Pan-European Presence

With offices in Barcelona, Madrid, Lisbon, and London, and a network of CRAs and regulatory experts across Europe, MDx provides localized insight with global reach—helping MedTech companies meet requirements faster and smarter.

The European MedTech sector is growing—but so are its regulatory challenges. Whether you’re launching a new diagnostic product or preparing for a Notified Body audit, MDx CRO is here to support your success every step of the way.

Let’s talk about your next clinical or regulatory challenge.

Further Reading

Industry Insights & Regulatory Updates

IVDR Transition for Precision Medicine: How MDx CRO Enabled a Seamless Portfolio Upgrade

Introduction to IVDR Transition for Precision Medicine

IVDR transition for precision medicine programs can stall when portfolios span liquid biopsy, RNA-based sequencing, and comprehensive tumor profiling. A leading US-based precision medicine company asked MDx CRO to migrate its oncology diagnostics from self-declared IVDD and FDA pathways to full IVDR certification—without disrupting European market access. This blog shares how we planned the transition, selected the right Notified Body, rebuilt regulatory files, and safeguarded ongoing clinical and CDx development in Europe.

The Challenge and how MDx CRO Enables a Seamless Portfolio Upgrade

  • Convert complex files from FDA/IVDD to IVDR. Multiple assay types (liquid biopsy, RNA-seq, tumor profiling) required re-evidence and restructuring under IVDR Annexes.
  • Select the optimal Notified Body. The client needed a partner capable of reviewing a diverse portfolio efficiently and cost-effectively.
  • Regulatory documentation lift. We had to redevelop key documents: analytical & clinical performance (including CPS reports), risk and design files, and labeling—while maintaining business continuity.

MDx CRO’s Approach to IVDR Transition

1) Strategic IVDR roadmap and portfolio triage

We assessed intended purpose, risk class, and evidence gaps for each product, then prioritized quick-win files to protect revenue while scheduling deeper re-verification work for complex assays. This created a clear IVDR transition for precision medicine timeline across the portfolio.

2) Notified Body strategy

Leveraging our knowledge of NB capacity and focus areas, we strategically selected a Notified Body that balanced approval probability, cost, and credibility. Early technical consultations reduced surprises and kept reviews on track.

3) Robust regulatory files

We generated comprehensive IVDR documentation:

  • Analytical and clinical performance reports, including scientific validity and performance evaluation reports
  • Risk management aligned to Annex I GSPRs
  • Design and development files with clear traceability
  • Usability and labeling aligned with intended purpose and user context

4) Operational partnership and sponsor duties

The client expanded our role into delegated sponsor responsibilities for clinical studies. We served as EU Legal Representative, oversaw clinical operations, and implemented streamlined processes for biomarker and CDx study submissions across Europe.

Results

  • Successful IVDR transition for priority diagnostics with uninterrupted market access in Europe.
  • Competitive advantage: stronger operational readiness helped the client attract pharma partners for clinical trial biomarker testing and CDx development.
  • Ongoing partnership: MDx CRO manages clinical studies, maintains sponsor duties, and continues the portfolio-wide IVDR journey.

Client Testimonial

“Working with MDx’s Precision Medicine Team has been a pleasure. As a U.S.-based company operating in Europe, I consider them our EU extension. Their expertise and responsiveness keep us ahead in a dynamic market, and the consistency of their delivery has shaped our current and future plans.”

Why This Matters

IVDR raises expectations for evidence, documentation, and lifecycle controls—especially for precision medicine diagnostics. Success requires portfolio triage, NB strategy, and regulatory files that stand up to scrutiny while your teams continue running trials and supporting pharma partnerships. MDx CRO brings integrated regulatory, clinical, and diagnostic know-how to keep your transition moving.

Planning an IVDR transition for precision medicine diagnostics? Let’s protect your market access, cut RFI cycles, and ready your files for Notified Body review.

Industry Insights & Regulatory Updates

IVDR for NGS Assays: 7 Key Compliance Challenges (and How to Solve Them)

TL;DR | What You Need to Know

NGS-based IVDs face unique IVDR compliance challenges, from validating bioinformatics pipelines under IEC 62304 to demonstrating scientific validity across thousands of genes. Most NGS assays classify as IVDR Class C or D, requiring Notified Body review, comprehensive performance evaluation, and lifecycle documentation. This article covers the 7 critical challenges and practical solutions, informed by MDx’s experience CE-marking one of the world’s first 4,600+ gene panels under IVDR.

Next-Generation Sequencing (NGS) has revolutionized molecular diagnostics by enabling simultaneous analysis of hundreds or thousands of genes across diverse clinical applications. These include germline testing for hereditary disorders, somatic mutation profiling in oncology, infectious disease characterization, and transcriptomic gene expression analysis.

A particularly impactful advancement is liquid-biopsy NGS, which allows non-invasive detection of tumor-derived nucleic acids, such as circulating tumor DNA (ctDNA) or RNA, from blood or other bodily fluids. This method now supports cancer screening, minimal residual disease monitoring, and therapy stratification.

NGS also powers Comprehensive Genomic Profiling (CGP). These assays assess a wide spectrum of biomarkers, single nucleotide variants (SNVs), insertions and deletions (indels), copy number alterations (CNAs), copy number losses (CNLs), gene fusions, and splicing events, across large panels in a single run. Many workflows also integrate microsatellite instability (MSI) and tumor mutational burden (TMB).

Assays can range from targeted panels to whole exome sequencing (WES) or whole genome sequencing (WGS). Each format carries unique validation needs and bioinformatics requirements. The mix of technologies, analytes, sample types (e.g., blood, plasma, FFPE, cfDNA, RNA), and clinical contexts increases regulatory complexity.

Under the EU In Vitro Diagnostic Regulation (IVDR; EU 2017/746), you must define each intended use clearly and support it with comprehensive evidence of scientific validity, analytical performance, and clinical performance. That requirement calls for a holistic, coordinated validation and documentation strategy.

For CE-marking manufacturers and clinical laboratories operating under Article 5(5), IVDR demands structured validation, clear documentation, and lifecycle management. For NGS-based assays, compliance becomes even more demanding due to scientific, technical, and operational intricacies.

Key Challenges in IVDR Compliance for NGS

1) Complex Gene Panels & Variant Diversity

NGS panels often include multiple genes and variant types, each with distinct performance characteristics. You must demonstrate analytical performance—sensitivity, specificity, LoD, and robustness—per variant class. This tailoring increases the scale and complexity of testing.

2) Defining a Clear Intended Use

A precise, testable intended purpose statement anchors the program. Define analytes, clinical context, sample types, output format, and role in patient care. Any ambiguity risks misclassification or validation gaps.

3) Scientific Validity Across Many Analytes and Conditions

Establishing scientific validity grows challenging when one test targets dozens or hundreds of genes. Under IVDR, link each analyte to a clinically relevant condition. That linkage often requires extensive literature review, database referencing, and written justification for inclusion.

4) Clinical Performance Evidence

With broad genomic scope, comprehensive clinical studies may be infeasible. A pragmatic approach combines routine diagnostic data, published literature, and a clear link to Post-Market Performance Follow-up (PMPF) plans to support claims over time.

5) Complex Bioinformatics Pipelines

Bioinformatics sits at the core of NGS diagnostics. Validate every step—from base calling to variant annotation. Implement version control, clear revalidation triggers, and change management to maintain consistent performance after software updates.

6) Use of Third-Party Reagents and Instruments

NGS workflows often incorporate off-the-shelf reagents and platforms not originally CE-marked as part of the IVD system. Document compatibility, performance, and traceability of third-party components to meet IVDR expectations.

7) Labelling Without a Physical Device

Many NGS assays function as software-driven services or LDTs without a packaged device. You still must meet Annex I labelling and Instructions for Use (IFU) requirements—even without physical labels or packaging.

How MDx CRO Supports Your IVDR Journey

MDx CRO brings specialized expertise to guide NGS programs through IVDR across the full lifecycle:

  • Gap Assessments: Identify regulatory shortfalls and prioritize remediation.
  • Performance Evaluation Plan (PEP): Craft PEPs that balance analytical rigor with operational feasibility.
  • Analytical Study Oversight: Design statistically robust studies tailored to complex panels.
  • Bioinformatics Validation: Map and validate each software component under IEC 62304 and ISO 13485.
  • QMS Integration: Build audit-ready documentation, risk management, and traceability.
  • PMS & PMPF Strategies: Establish real-world evidence systems that sustain compliance and support clinical claims.

Frequently Asked Questions

What IVDR class are NGS-based diagnostic tests?

Most NGS-based diagnostic tests fall into IVDR Class C because they typically provide high-risk individual patient information (e.g., germline disease or somatic mutation profiling). NGS assays used for infectious disease with high public health risk may classify as Class D. Classification depends on the specific intended use, clinical claims, and risk profile of each test.

How do you validate an NGS bioinformatics pipeline for IVDR compliance?

Under IVDR, bioinformatics pipelines must be validated as medical device software following IEC 62304 and IEC 82304-1. This includes documenting the software architecture, implementing version control and change management, verifying variant calling accuracy at each step (base calling, alignment, variant annotation), and establishing revalidation triggers for software updates. Risk management per ISO 14971 must also be integrated into the software lifecycle.

How do you demonstrate scientific validity for a large NGS gene panel under IVDR?

For large panels covering hundreds or thousands of genes, a tiered evidence strategy is recommended. This combines validation of exome sequencing as a methodology, reliance on curated public databases (e.g., ClinVar, OMIM) for gene-disease associations, and deep exemplar evidence for high-prevalence genes. Low-prevalence genes are supported through a structured Post-Market Performance Follow-up (PMPF) plan that matures evidence over time.

Do clinical laboratories running NGS LDTs need to comply with IVDR?

Yes. Under IVDR Article 5(5), EU health institutions manufacturing and using in-house IVDs (including NGS-based laboratory-developed tests) must meet six specific conditions: justification that no equivalent CE-marked device meets patient needs, ISO 15189-compliant QMS, alignment with IVDR General Safety and Performance Requirements, documentation of design and manufacture, and publication of a public declaration. Laboratories that cannot meet these conditions must pursue CE marking.

What are the biggest challenges in achieving IVDR compliance for NGS assays?

The seven key challenges are: (1) demonstrating analytical performance across complex gene panels and diverse variant types, (2) defining a precise intended use statement, (3) establishing scientific validity across many analytes, (4) generating clinical performance evidence at scale, (5) validating bioinformatics pipelines as medical device software, (6) documenting third-party reagents and instruments not originally CE-marked, and (7) meeting IVDR labelling requirements for software-based or service-based assays without a physical device.”

Conclusion

Achieving IVDR compliance for NGS assays poses a multi-dimensional challenge that blends regulatory discipline with scientific depth. From defining intended use to managing software changes and clinical claims, every step benefits from clarity, structure, and foresight.

MDx CRO partners with diagnostics developers and clinical laboratories to turn regulatory complexity into actionable validation strategies, accelerating time to market while protecting long-term compliance and patient safety.

Related Reading

Written by:
Marketa Svobodova, PhD

Marketa Svobodova, PhD

Regulatory Director, Precision Medicine

Expert in Precision Medicine, NGS & CDx, combining technical and regulatory expertise to guide IVDs through CE certification.
Industry Insights & Regulatory Updates

ISO 13485 Implementation Guide: How to Stand Up a World-Class QMS (and Win Faster Market Access)

For MedTech and diagnostics companies, ISO 13485:2016 is the operating system for quality. It’s the globally recognized standard that regulators and notified bodies expect you to use to design, manufacture, and maintain safe, effective devices across the full lifecycle. Implement it well and you accelerate technical documentation, reduce rework, and shorten time-to-market. Implement it poorly and every audit, change, and submission becomes harder than it should be.

There’s an additional strategic reason to act now: the U.S. FDA’s Quality Management System Regulation (QMSR) formally converges 21 CFR 820 with ISO 13485:2016. The QMSR’s effective date is February 2, 2026, with a two-year transition from the legacy QS Reg—so a robust ISO 13485 QMS positions you for both EU and U.S. expectations. (QMSR overview PDF).

What ISO 13485 actually requires (and how to build it right)

At its core, ISO 13485 demands a documented, controlled set of interrelated processes that meet regulatory requirements for medical devices—from design and production to post-market activities. Success is not about templates; it’s about process architecture, risk-based decision-making, and evidence you can defend. (ISO 13485 handbook preview).

1) Map your process architecture

Start with a top-level map that shows how design & development, purchasing/supplier control, production & service provision, software validation (for QMS and process software), vigilance, and post-market processes interact. Keep ownership clear; keep inputs/outputs traceable.

2) Make risk management the backbone

ISO 13485 expects risk-based controls throughout realization and post-market feedback. Operationalize ISO 14971:2019 (and ISO/TR 24971 guidance) so hazards, risk controls, and residual risk tie directly into design inputs, verification/validation, and change control.

3) Design controls that satisfy NB and FDA reviewers

Build a single D&D framework that covers planning, inputs/outputs, reviews, verification, validation (including clinical/performance where applicable), transfer, and DHF/Design History File traceability. Link your design plans to intended purpose/indications so your technical documentation aligns with MDR/IVDR and (when applicable) FDA submissions.

4) Supplier & software rigor

Qualify and monitor critical suppliers with risk-based controls; embed incoming inspection and performance metrics. Validate QMS/production software proportional to risk and document configuration management so you can pass objective evidence reviews.

5) Document control that scales

Use a lean document hierarchy (policy → process → work instruction → form) and number it so auditors can navigate quickly. Automate change control and training effectiveness checks; link each controlled record to the process requirement it satisfies.

6) Post-market surveillance that drives improvement

Your PMS loop should systematically capture complaints, feedback, vigilance, field actions, and real-world performance. Close the loop with CAPA and management review using trend analysis and risk re-evaluation.

7) Internal audits and management review that add value

Audit for process performance (not just procedural conformance). Track effectiveness KPIs and feed them into management review alongside regulatory metrics (e.g., NB queries, submission outcomes, vigilance timelines).

EU alignment matters: harmonized EN ISO 13485 and MDR/IVDR

In Europe, EN ISO 13485:2016 (including A11:2021 and AC:2018) is recognized as a harmonized standard supporting MDR/IVDR requirements—useful for presumption of conformity where applicable. Aligning your QMS to the harmonized edition reduces friction in notified body assessments and surveillance.

Implementation roadmap (what works in the real world)

  • Phase 1 — Gap Assessment & Plan: Benchmark current practices against ISO 13485 clauses, ISO 14971 integration points, and your market strategy (EU MDR/IVDR, FDA QMSR). Produce a prioritized remediation plan with owners and dates.
  • Phase 2 — Process Build & Evidence: Draft/revise procedures; pilot them with one product line to generate real records (design plan, risk files, supplier files, software validation, training, internal audit).
  • Phase 3 — System Activation: Roll out across programs; execute internal audit cycle and management review with measurable outcomes.
  • Phase 4 — NB/FDA Readiness: Run a mock audit; fix systemic findings; align technical documentation index to QMS records; confirm personnel qualification and training effectiveness.

Avoid the top 5 pitfalls we see

  • Building dozens of procedures without a process map (auditors get lost; so do teams).
  • Treating risk management as a document, not a process that drives design and post-market decisions.
  • Weak supplier controls for critical components and software.
  • Software validation that stops at IQ/OQ and misses real-world configurations.
  • “One-and-done” internal audits that don’t test effectiveness or feed CAPA.

How MDx CRO makes ISO 13485 implementation faster (and audit-proof)

MDx CRO designs right-sized 13485 systems for MedTech and diagnostics teams—from first-time implementations to remediation before NB or FDA inspections. We build the process architecture, author and train on lean SOPs, integrate ISO 14971 risk into day-to-day decision-making, and generate submission-ready evidence. Then we run mock audits that mirror NB/FDA styles so you walk into the real thing prepared.

Explore Regulatory & Quality Services and Clinical & Post-Market Support, or contact MDx CRO to scope your ISO 13485 program.

Industry Insights & Regulatory Updates

A Step-by-Step Guide to IEC 62366 and Usability Engineering

The usability of medical devices is not just a matter of convenience. It is a matter of safety, effectiveness, and regulatory compliance. Poor design that confuses or frustrates users can lead to use errors, adverse events, and even patient harm. To address this, the international standard IEC 62366-1:2015/Amd 1:2020 establishes a structured framework for usability engineering in medical device development.

For medical device manufacturers, understanding and applying IEC 62366 is essential. Compliance demonstrates that usability risks have been identified, reduced, and documented, which is essential for all medical devices including IVDs and Software as a Medical Device (SaMD).

What Is IEC 62366?

IEC 62366 is the internationally recognised standard that defines how to integrate usability into the design and development process.

It has two main parts:

  • IEC 62366-1:2015/Amd 1:2020 Medical devices – Application of usability engineering to medical devices: The core standard describing the usability engineering process.
  • IEC/TR 62366-2:2016 Medical devices – Guidance on the application of usability engineering to medical devices: A technical report providing guidance and examples to support implementation.

The goal is to ensure that usability engineering is applied consistently so that devices can be used safely and effectively by intended users, in intended use environments, while ensuring that use errors that could lead to harm are identified, reduced, and controlled through structured usability activities.

Why Usability Engineering Matters

Use-related errors are a leading cause of device-related adverse events. By embedding usability engineering into product development, manufacturers can:

  • Reduce use errors that could lead to harm
  • Improve patient safety and treatment outcomes
  • Satisfy regulatory requirements from the MDR, IVDR, and FDA
  • Increase user acceptance and market success
  • Lower long-term costs by avoiding redesigns or recalls

In short, usability is both a compliance requirement and a competitive advantage.

Step-by-Step Guide to Applying IEC 62366

The usability engineering process defined in IEC 62366 is systematic and iterative. It integrates into the overall product development lifecycle and risk management process in line with ISO 14971. Below is a step-by-step breakdown.

Step-by-step visual guide illustrating the IEC 62366 usability engineering process for medical devices, covering intended use definition, hazard identification, risk analysis, user interface requirements, formative evaluations, and summative usability validation, aligned with EU MDR and FDA human factors guidelines.

The UEF is the central documentation repository for all usability activities. It includes intended use, user profiles, use scenarios, hazard analysis, test results, and risk control measures. In practice, the records and other documents that form the UEF may also form part of the product design file (ISO 13485) or the risk management file (ISO 14971).

Think of the UEF as both a project management tool and evidence for regulators.

Prepare the Use Specification. This is where you define:

  • The intended medical purpose of the device
  • The user groups (e.g. clinicians, patients, laypersons, caregivers)
  • The use environments (hospitals, homes, ambulances, clinics)
  • Any training or expertise required

This forms the foundation of all subsequent usability activities.

Once you know who will use your device and where, the next step is to analyse how things could go wrong.

Activities include:

  • Identifying safety-related user interface characteristics (e.g. readability of displays, button layout, alarm visibility).
  • Reviewing post-production data and public databases for known usability issues with similar devices.
  • Identifying hazards and hazardous situations.
  • Identifying and describing hazard-related use scenarios, which describe exactly how use errors might occur and what consequences they could have.
  • Selecting hazard-related use scenarios for Summative Evaluation.

These scenarios are then prioritised to decide which will be evaluated in summative testing.

This is where design and usability testing happen in iterative cycles.

Key steps:

  1. Establish the User Interface Specification – the blueprint of all UI elements.
  2. Develop the User Interface Evaluation Plan – define how formative and summative testing will be performed.
  3. Iterative cycles of concept, prototype, and testing

The point of formative evaluation is to find usability issues early, before final validation, so changes are cheaper and less disruptive.

The final stage is a summative usability validation. This is a formal test that demonstrates to regulators that the device can be used safely and effectively by the intended users.

  • Test the hazard-related use scenarios identified earlier.
  • Use representative users in realistic environments.
  • Collect both objective performance data (task completion, error rates) and subjective feedback (ease of use, confidence).
  • Confirm that residual risks are acceptable in line with ISO 14971.

This stage provides the objective evidence regulators require to ensure compliance.

Usability engineering does not end at product launch. Post-market surveillance should collect feedback on usability issues, adverse events, and complaints. Updates or design changes may be required if new risks emerge.

Common Challenges in Applying IEC 62366

Many manufacturers encounter difficulties such as:

  • Underestimating resources needed for usability testing
  • Recruiting representative users for formative and validation studies
  • Defining realistic use scenarios that reflect actual clinical environments
  • Integrating usability with development timelines
  • Documenting evidence properly in the UEF

Failing to address these challenges can result in regulatory rejection, delays, or costly redesigns.

Best Practices for Success

  1. Start usability engineering early in the design process
  2. Involve multidisciplinary teams including engineers, clinicians, and usability experts
  3. Use a mix of qualitative and quantitative methods in evaluations
  4. Prioritise hazard-related use scenarios in validation testing
  5. Document everything thoroughly in the Usability Engineering File
  6. Where possible involve regulators early for alignment
  7. Leverage specialist expertise such as a Medical Device and IVD Consultancy with usability engineering experience
Does the FDA also recognise IEC 62366?

Yes. The latest versions of the IEC 62366 standards are recognised by the FDA as consensus standards. However, the FDA has also published specific human factors engineering guidances with minor differences to IEC 62366 so it is recommended that these are also considered for FDA submissions.

When should usability testing be performed?

Throughout development. Formative evaluations identify and correct issues early, while summative validation confirms safe and effective use before market approval.

Can simulated environments be accepted in usability validation?

Yes, provided they are representative of real-world conditions and cover all critical tasks and hazard-related use scenarios.

What is the difference between IEC 62366-1 and IEC 62366-2?

EC 62366-1 is the main normative standard that defines the usability engineering process manufacturers must follow. IEC 62366-2 is a companion informative document that provides guidance and rationale to help apply IEC 62366-1 in practice. For regulatory submissions, compliance with IEC 62366-1 is what notified bodies and regulators assess — IEC 62366-2 is a supporting resource, not a requirement.

What must be included in a Usability Engineering File?

The Usability Engineering File (UEF) is the core documentation output of the IEC 62366-1 process. It must document the intended use and user groups, use scenarios and user interface specification, formative evaluation records, summative evaluation plan and results, and risk-related findings and how they were addressed. It should be structured to allow a notified body or regulatory reviewer to trace the full usability engineering process from start to finish.

Does IEC 62366 apply to IVDs?

Yes. IEC 62366-1 applies to all medical devices, including in vitro diagnostic devices (IVDs). Under the EU IVDR and MDR, manufacturers are expected to demonstrate that human factors and usability have been considered as part of the design and development process. This is particularly relevant for IVDs used at the point of care or by lay users, where use errors can have direct patient safety implications.

How many participants are needed for a summative usability study?

There is no fixed number mandated by IEC 62366-1, but common practice — and FDA guidance — typically expects a minimum of 15 participants per user group for summative evaluations. The number should be justified based on the diversity of the user population, the complexity of the device, and the number of critical tasks being evaluated. For high-risk devices or large user populations, a larger sample may be required.

What is the difference between a formative and summative evaluation?

Formative evaluations are iterative assessments carried out during device development to identify and resolve usability problems early. They are exploratory in nature and do not need to meet a pre-defined pass/fail criterion. Summative evaluations, also called validation testing, are conducted on a near-final or final version of the device to confirm that users can operate it safely and effectively without being coached or corrected. Summative results are what get submitted to regulators.

How MDx CRO Can Help

Implementing IEC 62366 in-house can strain resources. At MDx CRO we can provide:

  • Protocol development and study design for usability testing
  • Recruitment of representative users across geographies
  • Moderation of formative and validation studies
  • Integration of usability engineering with regulatory strategy
  • Preparation of all usability documentation required for submissions including FDA submissions

As a trusted Medical Device and IVD consultancy, we support manufacturers in implementing IEC 62366, running usability studies, and preparing documentation that satisfies both EU and US regulators. Whether you are starting a new project or updating an existing device, our team helps you achieve compliance and deliver safer devices to market.

Need help with IEC 62366 compliance?

Talk to our usability engineering team.

Full Name
(Include device type, current challenge, or regulatory stage)
We respect your privacy. All information submitted will 
remain confidential.
Checkboxes
Written by:
Floella Otudeko

Floella Otudeko

Senior QARA Specialist

Senior QA/RA consultant with MDR, IVDR, Usability/Human Factors and MDSW expertise, supporting MedTech and IVD innovation globally.
Industry Insights & Regulatory Updates

IVDR Clinical Performance Studies: A Complete Guide to ISO 20916 Compliance

The In Vitro Diagnostic Regulation (IVDR EU 2017/746) has redefined the requirements for bringing invitro diagnostic (IVD) devices to the European market. Compared with the previous IVD Directive, most devices are now subject to higher classification, more rigorous oversight, and stricter evidence requirements.

At the heart of these new obligations lies the clinical performance study. To comply with IVDR, manufacturers must demonstrate that their devices perform safely and effectively in real-world conditions. The standard ISO 20916:2024 sets the benchmark for conducting these studies to recognised international good practice.

In this article, we’ll explore what clinical performance studies are, why they matter under IVDR, the role of ISO 20916, and how manufacturers can successfully run studies to secure CE marking and maintain market access.

What Is a Clinical Performance Study?

A clinical performance study is an investigation carried out to establish how an IVD performs using human specimens. Unlike laboratory-based analytical performance tests, clinical performance studies focus on real-world clinical outcomes:

  • Does the device detect the intended condition accurately?
  • Does it provide reproducible and reliable results in the target population?
  • Is its performance clinically meaningful for diagnosis or monitoring?

In regulatory terms, clinical performance means the device’s ability to yield results that correlate with a specific clinical condition or physiological state. Under IVDR, Clinical Performance Studies provide essential evidence to confirm this performance.

Why Clinical Performance Studies Are Critical Under IVDR

The IVDR dramatically increases the need for robust clinical evidence:

  1. Higher device classification – Many IVDs previously self-certified under the IVD Directive now require Notified Body review.
  2. Performance evaluation requirements – Clinical performance is one of the three pillars of evidence (alongside scientific validity reports for EU IVDR submission and analytical performance) outlined in IVDR Article 56.
  3. Regulatory approval and CE marking – Without a compliant Clinical Performance Study, manufacturers risk delays or refusal of certification.
  4. Market competitiveness – Strong clinical data builds confidence with regulators, clinicians, and end-users.

Put simply: no strong clinical evidence, no EU market access.

The Role of ISO 20916

ISO 20916 provides the internationally recognised framework for running Clinical Performance Study.

The standard sets out requirements across the study lifecycle, including:

  • Planning: Protocol design, objectives, endpoints, sample size, and bias control
  • Ethics: Protecting participant rights, safety, and data privacy in line with the Declaration of Helsinki and GDPR
  • Conduct: Investigator qualification, site selection, specimen handling, and monitoring
  • Data integrity: Ensuring quality, traceability, and Good Clinical Practice oversight
  • Reporting: Producing structured, regulator-ready study reports

By following ISO 20916, manufacturers can ensure their Clinical Performance Study meet both IVDR requirements and global best practice. This reduces the risk of regulatory rejection.

Key Components of a Clinical Performance Study

1. Study Planning and Protocol Development

Every Clinical Performance Study begins with a comprehensive study protocol, which must define:

  • Study objectives and endpoints.
  • Target population and specimen types.
  • Statistical methodology and sample size.
  • Ethical and data protection considerations.

A strong protocol is the backbone of a successful Clinical Performance Study.

2. Regulatory and Ethical Approvals

Before starting, approvals must be obtained from:

  • Ethics committees – Ensuring participant protection.
  • Competent authorities – Depending on Member State requirements and risk of the study.

For example, interventional clinical performance studies require competent authority approval, whereas observational, non-invasive studies may only require ethics approval.

Timelines vary across the EU, so early planning is essential. MDx can act as your study legal representative in the EU.

3. Study Design Options

Common approaches include:

  • Prospective studies – Collecting new samples directly from participants.
  • Retrospective studies – Using existing, stored, or leftover samples.
  • Multicentre studies – Increasing robustness and diversity of data.

The chosen design must reflect the device’s intended use and risk class.

4. Specimen Management

The validity of results depends heavily on proper specimen handling. ISO 20916 requires:

  • Documented collection procedures.
  • Controlled storage and transport.
  • Full traceability from donor to result.

5. Data Capture and Monitoring

Accurate and reliable data is non-negotiable. Clinical Performance Study should use:

  • Validated electronic data capture systems.
  • On-site and remote monitoring.
  • Independent oversight where appropriate.

6. Statistical Analysis

Predefined statistical methods must cover:

  • Sample size calculations.
  • Handling of missing or invalid data.
  • Robust evaluation of endpoints.

7. Reporting and Submission

At study close, results are documented in a Clinical Performance Study Report (CPSR). This feeds into the Performance Evaluation Report (PER), a mandatory element of IVDR technical documentation reviewed by Notified Bodies.

Common Challenges in Running a Clinical Performance Study

Acoording to Floella Otudeko, many manufacturers encounter obstacles, including:

  • Navigating complex approval processes across different EU Member States.
  • Recruiting enough suitable participants within target populations.
  • Coordinating specimen collection, transport, and storage logistics.
  • Addressing GDPR compliance for personal and health data.
  • Aligning study expectations with Notified Bodies to avoid re-work.

Without careful planning, these issues can lead to costly delays.

Best Practices for Successful Clinical Performance Study

  1. Where possible, engage early with regulators and Notified Bodies to avoid surprises.
  2. Develop a robust protocol that anticipates operational and statistical challenges.
  3. Invest in investigator training to maintain study consistency.
  4. Implement real-time monitoring to catch issues before they escalate.
  5. Document everything thoroughly for audit readiness.
  6. Seek external expertise where internal resources are limited.

How a IVD MedTech CRO Adds Value

Running a compliant Clinical Performance Study is resource intensive. Partnering with a specialist consultancy like MDx CRO can help by:

  • Designing protocols aligned with ISO 20916 and IVDR requirements.
  • Managing submissions to ethics committees and competent authorities.
  • Overseeing study conduct across multiple sites and geographies.
  • Ensuring GDPR-compliant data management.
  • Engaging with Notified Bodies through structured dialogues to align on expectations early.

Leading to faster approvals, stronger evidence, and smoother market access.

Concluding Remarks

Running a clinical performance study under IVDR is not just a regulatory box-ticking exercise, it is the foundation of market approval and long-term trust in your device. ISO 20916 provides the global standard for good study practice, ensuring that evidence is ethically gathered, scientifically robust, and regulator ready.

For IVD manufacturers, the journey can be challenging, but with the right planning and support, it becomes an opportunity to demonstrate value, accelerate approvals, and build credibility with clinicians and patients alike.

As an experienced full service IVD MedTech CRO partner, MDx helps companies design, conduct, and report clinical performance studies. We pay special attention to meet both regulatory demands and business objectives. Whether you are preparing your first IVDR submission or adapting existing devices, our team provides the expertise and operational support you need to succeed.

Read more about our IVD clinical performance study services.

FAQ

Do all IVDs require a clinical performance study under IVDR?

Not always. The need depends on the device’s risk class, intended use, and existing evidence. However, most devices now require stronger clinical evidence than under the previous directive, and many will need new or updated clinical performance data reviewed by a Notified Body.

What is the difference between analytical performance and clinical performance?

Analytical performance shows how well the test works in controlled laboratory conditions (accuracy, precision, limits of detection). Clinical performance demonstrates that the device’s results correlate with a specific clinical condition or physiological state in the intended population. Both are mandatory components of the IVDR performance evaluation, alongside scientific validity.

When is Competent Authority approval required?

Interventional clinical performance studies generally require approval from both an ethics committee and the relevant Competent Authority. Observational, non-interventional studies may only require ethics approval, depending on the Member State. Early planning is essential because timelines vary across the EU.

How does ISO 20916 support IVDR compliance?

ISO 20916 provides the internationally recognised framework for designing, conducting, monitoring, and reporting clinical performance studies. Following it helps ensure ethical conduct, data integrity, and regulator-ready documentation aligned with IVDR expectations.

What are the most common reasons studies face delays?

Delays often stem from incomplete protocols, misalignment with Notified Bodies, slow ethics or authority approvals, recruitment challenges, and GDPR-related data issues. Clear planning, predefined statistical methods, and strong documentation reduce the risk of rework.

What happens after the study is completed?

Results are compiled into a Clinical Performance Study Report (CPSR), which feeds into the Performance Evaluation Report (PER). The PER forms part of the IVDR technical documentation reviewed by the Notified Body for CE marking.

Can a CRO support the process?

Yes. A specialised IVD MedTech CRO can design IVDR-aligned protocols, manage regulatory submissions, oversee multicentre operations, ensure GDPR-compliant data management, and engage early with Notified Bodies—reducing risk and accelerating time to market.

Written by:
Floella Otudeko

Floella Otudeko

Senior QARA Specialist

Senior QA/RA consultant with MDR, IVDR, Usability/Human Factors and MDSW expertise, supporting MedTech and IVD innovation globally.
Industry Insights & Regulatory Updates

A CRO’s Guide to IVD Analytical Validation: Best Practices & Common Pitfalls

Mastering IVD Analytical Validation Under IVDR

Analytical validation is the cornerstone of in vitro diagnostic (IVD) development. Under the European Union’s In Vitro Diagnostic Regulation (IVDR; EU 2017/746), it provides evidence that an IVD device performs as intended—accurately, reliably, and consistently within its defined scope. For both CE-marking manufacturers and laboratories operating under Article 5(5), analytical validation sits at the center of the performance evaluation framework in Article 56 and Annex XIII.

Core Parameters of Analytical Performance

The IVDR requires a full demonstration of the analytical performance characteristics in Annex I, Section 9.1(a). These include:

  • Trueness (Bias): Closeness of agreement between measured values and a reference (ISO 5725-1; JCGM 200:2012).
  • Precision: Repeatability and reproducibility across instruments, operators, and time (CLSI EP05-A3; ISO 20776-2).
  • Accuracy: Combination of trueness and precision; essential for reliable results.
  • Analytical Sensitivity (Limit of Detection, LoD): Smallest analyte amount distinguishable from background (CLSI EP17; MM06).
  • Analytical Specificity: Ability to measure only the target analyte, avoiding cross-reactivity and interference (ISO 15193; CLSI MM09, MM26).
  • Linearity: Proportional response across a defined concentration range (CLSI EP06, EP10).
  • Limit of Quantification (LoQ): Minimum (and where relevant maximum) concentrations quantifiable with acceptable error.
  • Cut-off Values: Thresholds separating positive from negative results (CLSI EP12, EP24).
  • Reportable Range: Span of values that the assay can report reliably.
  • Metrological Traceability: Link results to references through a documented calibration chain (JCGM 200:2012).
  • Stability: Shelf-life and in-use stability (ISO 18113-1; EN ISO 23640).
  • Specimen Type & Stability: Validate all relevant sample types and storage conditions (CLSI M47).

If a parameter does not apply, provide robust justification. Regulators expect clear reasoning. Use harmonized standards and consistent definitions wherever possible. The CLSI Harmonized Terminology Database helps align terminology across documents and communications.

Challenges and Common Pitfalls

  • Ambiguity in Intended Use: Vague claims misalign studies and weaken evidence.
  • Suboptimal Study Design: Studies should be statistically powered with predefined acceptance criteria.
  • Uncontrolled Pre-analytical Variables: Validate collection, transport, and storage; justify them in the Performance Evaluation Plan (PEP).
  • Software Validation Gaps: Algorithm-driven IVDs require software lifecycle controls (IEC 62304; IEC 82304-1).
  • Inadequate Traceability: Link raw data to the Analytical Performance Report (APR) and Performance Evaluation Report (PER).
  • Lifecycle Oversight: Changes to reagents, software, or protocols may trigger revalidation. Maintain PMS and PMPF to stay compliant.

Strategic Solutions

At MDx CRO, teams combine regulatory, scientific, and statistical expertise to streamline analytical validation. Key services include:

  • Gap assessments against IVDR, MDCG, and CLSI guidance.
  • Custom analytical study design aligned with ISO 13485 and Annex XIII.
  • Software validation support with cybersecurity oversight.
  • Technical file preparation for Notified Body review.
  • Integration of PMS and PMPF into performance lifecycle management.

Conclusion

Analytical validation is more than a regulatory obligation—it forms the foundation of diagnostic credibility. When executed well, it shows that an IVD is accurate, safe, and clinically effective. With IVDR bringing heightened scrutiny, manufacturers should use clear definitions, rigorous justifications, and harmonized standards to achieve strong validation and long-term market success.

Need help building audit-ready analytical validation under IVDR? MDx CRO designs compliant studies, strengthens traceability, and prepares technical files for faster, smoother reviews. Contact us today.

Written by:
Marketa Svobodova, PhD

Marketa Svobodova, PhD

Regulatory Director, Precision Medicine

Expert in Precision Medicine, NGS & CDx, combining technical and regulatory expertise to guide IVDs through CE certification
Industry Insights & Regulatory Updates

MDx CRO co-authors Journal of Liquid Biopsy paper on EU–US collaboration for IVDR-ready liquid biopsy validation

MDx CRO is proud to have contributed to the peer-reviewed article, “BLOODPAC’s collaborations with European Union liquid biopsy initiatives,” published in The Journal of Liquid Biopsy (Vol. 10, Article 100321; open access). The paper outlines practical pathways to align analytical validation, clinical performance evidence, and data standards that can accelerate European adoption of liquid biopsy under IVDR.

Carlos Galamba (CEO, MDx CRO) is listed among the authors, contributing European IVDR and clinical evidence expertise to this multi-stakeholder effort.

What the paper delivers (and why it matters)

  • Convergence on validation & evidence: It maps BLOODPAC’s US-developed minimum technical data elements and analytical validation protocols to EU needs—supporting more consistent clinical performance packages for IVDR submissions.
  • Data standards for reproducibility: The paper emphasizes fit-for-purpose standards and pre-competitive data sharing to improve comparability across clinical research for liquid biopsy, from cfDNA/ctDNA assay development to clinical use.
  • Practical EU–US collaboration: It proposes guidance and collaboration routes that can reduce variability across Member States and shorten time to patient access—without compromising IVDR rigor.

A broad coalition behind the work

The author affiliations span leading precision-medicine organizations and networks, including MDx CRO, Labcorp, Tempus AI, Natera, Exact Sciences, AstraZeneca, GSK, Bristol Myers Squibb, Johnson & Johnson, MSD, Thermo Fisher Scientific, TECAN, IQN Path, ELBS, EUCOPE, ISLB, Cancer Patients Europe, and BLOODPAC—a clear reflection of the field’s momentum toward shared, usable guidance.

MDx CRO’s contribution and perspective

Through our CEO, Carlos Galamba, MDx CRO contributed to this multi-stakeholder paper outlining practical EU–US collaboration to accelerate liquid biopsy adoption under IVDR. Our perspective aligns with the paper’s focus on:

  • IVDR-first evidence architecture that cleanly links intended use → analytical validation → clinical performance requirements for ctDNA/cfDNA assays.
  • Harmonized validation expectations by mapping BLOODPAC frameworks and data elements to EU evidence needs, supporting consistent submissions.
  • Clearer regulatory narratives that connect validation outcomes to performance claims and real-world clinical implementation.

“This contribution reflects MDx’s commitment to turning shared frameworks into credible, IVDR-ready evidence that speeds responsible patient access” – Carlos Galamba, CEO

For IVD developers: immediate takeaways

Think trans-Atlantic. Where appropriate, re-use US learnings and BLOODPAC frameworks to reduce duplication—while meeting EU requirements.

Design for IVDR from day zero. Lock pre-analytical variables and analytical validation plans that ladder to clinical performance claims.

Adopt shared data elements. Standardized data models future-proof submissions and enable cross-study comparisons for regulators and payers.

How we execute: turning frameworks into IVDR-ready evidence

1) Study architecture (IVDR-first)

We design from intended use → analytical validationclinical performance so claims, endpoints, and statistics line up from day one. For liquid biopsy (cfDNA/ctDNA), we predefine fit-for-purpose metrics (e.g., LoD/LoQ, precision, interference) and clinical endpoints (e.g., PPA/NPA, sensitivity/specificity).

2) Multisite execution (ISO 20916 aligned)

Feasibility and qualification of sites/labs, standardized pre-analytical controls (collection tubes, processing windows, storage), specimen logistics and chain-of-custody, risk-based monitoring, and documented deviation/CAPA management across centers.

3) Data you can trust (eCRF + eTMF)

We build validated eCRFs, enforce edit checks and audit trails, and maintain a complete eTMF/regulatory binder. Data dictionaries align with study objectives and, where appropriate, community data elements used in clinical research for liquid biopsy.

4) Analytical validation to clinical performance—without gaps

We run or coordinate liquid biopsy validation workstreams (method comparisons, reproducibility, cross-site concordance) and transition seamlessly into clinical performance studies so the evidence package is coherent under IVDR.

5) Reporting & regulatory narrative

IVDR-compliant documentation (Analytical Performance Report, Performance Evaluation Plan/Report, study reports), plus clear narratives that connect results to performance claims and labeling.

6) Governance & quality

Project governance with milestone dashboards, risk logs, vendor oversight, and audit-ready files under an ISO-driven clinical QMS.

Outcome: faster, cleaner submissions for IVDR liquid biopsy validation—and evidence that stands up to scrutiny.

Plan a study? Let’s map your assay’s intended use to the analytical validation and clinical performance evidence you’ll need.

Industry Insights & Regulatory Updates