MDR vs. IVDR: What Are the Differences in QMS Requirements?
The MDR and IVDR impose extensive requirements on quality management and regulatory processes. Some processes vary depending on the product class.
Metecon supports manufacturers, laboratories, and regulated organizations in establishing, optimizing, and implementing audit-ready quality management systems. We organize processes, responsibilities, and documentation into a structure that transparently reflects the requirements of ISO 13485, ISO 15189, MDR/IVDR, MDSAP, or ISO 9001—while remaining practical for day-to-day operations. The goal is a QMS that is both compliant with the standards and pragmatic.
25+ years of QMS experience · 125+ SOPs/processes developed · 40+ audit readiness checksMetecon supports manufacturers, laboratories, and regulated organizations in establishing, optimizing, and implementing audit-ready quality management systems. We organize processes, responsibilities, and documentation into a structure that transparently reflects the requirements of ISO 13485, ISO 15189, MDR/IVDR, MDSAP, or ISO 9001 in a transparent manner while remaining practical for day-to-day operations. During audits, we assist with preparation, support during the audit, and follow-up—and help thoroughly analyze the causes of nonconformities and to effectively implement corrective actions.
Challenge 1 · Formal vs. Reliable
Processes are interpreted differently, circumvented, or not properly documented.
Metecon Solution: We embed processes so that they are actually followed in day-to-day operations and properly documented —implemented in practical manner rather than merely described.
Challenge 2 · Recurring Nonconformities
CAPA measures resolve symptoms but do not address the root causes within the process system.
Metecon Solution: Thorough root cause analysis and effective measures that target the root cause within the process—not the symptom.
Challenge 3 · Requirements Managed in Parallel
Normative, regulatory, and organizational requirements are managed in parallel rather than consolidated.
Metecon Solution: A robust QMS that consolidates all requirements into a single integrated management system.
An audit- and certification-ready quality management system in accordance with ISO 13485 is the foundation for MDR and IVDR compliance. Metecon develops, structures, and optimizes QMS processes as the basis for market readiness in Europe and international markets.
ISO 13485-compliant QMS setup, including a quality manual, SOPs, document control, and audit-ready process structures compliant with MDR and IVDR.
in accordance with ISO 13485, clause 8.2.4, to prepare for certification and surveillance audits.
Preparation for MDSAP, FDA-QMSR, and international audit programs for the U.S., Canada, Australia, Brazil, and Japan.
Support for medical laboratories in obtaining ISO 15189 accreditation and establishing audit-ready laboratory processes in accordance with ISO 15189.
Metecon supports you with a structured QMSR gap analysis.
The MDR and IVDR impose extensive requirements on quality management and regulatory processes. Some processes vary depending on the product class.
| Criterion | QMS under the MDR (Medical Devices) | QMS under the IVDR (IVDs) |
| Legal Basis | MDR (EU) 2017/745, Article 10 & Annexes IX and XI | IVDR (EU) 2017/746, Article 10 & Annexes IX and XI |
| Risk Classes | I, IIa, IIb, III (conformity assessment without a Notified Body for class I) | A, B, C, D (conformity assessment without a Notified Body for class A) |
| Internal Audits | risk-based, in accordance with ISO 13485 clause 8.2.4 + MDR Article 10 & Annexes IX and XI, Section 2.2 | risk-based, in accordance with ISO 13485 8.2.4 + IVDR Article 10 & Annexes IX and XI, Section 2.2 |
| CAPA Requirement | CAPA processes in accordance with ISO 13485, clause 8.5 | identical requirements in accordance with ISO 13485, clause 8.5 |
| Post-market surveillance | in accordance with the MDR, Chapter VII, including clinical evaluation | in accordance with IVDR, Chapter VII, including performance evaluation |
| Laboratory requirements | — | ISO 15189, relevant for medical laboratories |
| International requirements | MDSAP · FDA-QMSR · ISO 13485:2016 | identical requirements in accordance with MDSAP · FDA-QMSR · ISO 13485:2016 |
| Transition periods | Depending on the risk class and existing certificates for medical devices, by December 31, 2028, at the latest | Depending on the risk class and existing certificates for the IVDs, by December 31, 2029, at the latest |
Audit-ready quality management systems for medical devices in accordance with the MDR and ISO 13485—prepared in a structured manner for certification, surveillance, and supplier audits.
Structured audit programs in accordance with ISO 13485 clause 8.2.4 and ISO 19011—conducted by experienced lead auditors from the Metecon team.
Professional planning and conduct of internal QMS audits in accordance with ISO 13485 and the MDR—including audit programs, audit execution, document review, and structured audit reports. As an independent external auditor, Metecon assists with preparations for certification and surveillance audits.
Establish a supplier qualification system; provide support in preparing for audits of suppliers of critical components and outsourced processes: Define audit criteria. Provide input for the audit agenda. Conduct the audit, prepare the audit report, and maintain the approved supplier list. Provide assistance in evaluating the audit results.
Preparation for the certification audit or recertification audit: mock audit, document review, closing identified process gaps, employee briefing.
Notified Bodies expect audits to comply with ISO 19011 as the state of the art. Metecon audits follow the guidelines for management system audits according to ISO 19011:2018: a structured audit plan, structured selection of relevant processes and audit areas, document review, opening meeting, audit report, and follow-up.
Process analysis of existing processes with respect to MDR and ISO 13485 requirements; establishment of audit-ready processes; risk-based audit program with prioritization of critical processes
Structured tracking of audit-related actions and documented corrections within the quality management system in accordance with ISO 13485.
The Medical Device Single Audit Program covers FDA, Health Canada, TGA, ANVISA, and PMDA requirements with a single audit—ideal for export-oriented manufacturers.
MDSAP is an international audit program for medical device manufacturers that sell their products in Australia, Canada, the U.S., Brazil, and/or Japan.
Country-specific regulatory requirements and QMS requirements are assessed in a single audit.
Metecon prepares your QMS for MDSAP and guides you through the audit process.
Effective February 2, 2026, 21 CFR Part 820—the FDA Quality Management System Regulation (QMSR)—is based on ISO 13485:2016. ISO 13485-certified manufacturers thus meet a large portion of the FDA requirements. Metecon conducts your QMSR gap analysis—with a specific action plan for remaining FDA requirements.
QMS requirements for the Canadian market: Medical Device Regulations (SOR/98-282, Part 1, CMDR), ISO 13485 compliance.
TGA-compliant QMS documentation for Australia. Support for other regulatory markets, including PMDA (Japan), ANVISA (Brazil), and GCC/Middle East, is available upon request.
Since Brexit, the United Kingdom has its own regulatory requirements: the UK Medical Device Regulations (UKMDR) with UKCA marking. The ISO 13485-compliant QMS remains the foundation but must be adapted to meet UK-specific requirements (MHRA). Metecon supports companies in preparing for UKMDR compliance.
Manufacturers with a presence in the U.S. market should review their existing QMS processes for potential adjustments in light of regulatory changes.
We are familiar with the key audit areas of Notified Bodies and will prepare you and your QMS specifically for certification and surveillance audits.
Practical experience gained from real-world certification projects and from a manufacturer’s perspective—pragmatic and compliant with regulatory requirements.
A clear action plan with prioritized measures and a transparent assessment of regulatory risks.
Software-independent consulting on the selection and implementation of a digital QMS—MDR/IVDR-compliant.
Audit-ready quality management systems for IVD manufacturers in accordance with the IVDR and ISO 13485 – implementation of QMS requirements and regulatory processes.
Class D through December 31, 2027 · Class C through December 31, 2028 · Class B through December 31, 2029. A certified quality management system in accordance with ISO 13485 is required for the conformity assessment procedures for these IVD classes.
Establishment or optimization of an IVDR-compliant quality management system in accordance with ISO 13485 and IVDR Article 10—including roles, responsibilities, and documented regulatory process control.
Establishment or optimization of an IVDR-compliant quality management system in accordance with IVDR Article 10 and Annex IX or XI and ISO 13485—including the integration of regulatory documentation and evaluation processes in a manner that is audit-ready.
Structured handling of documented nonconformities and audit findings within the quality management system in accordance with ISO 13485 and the IVDR.
Internal QMS audits in accordance with ISO 13485, with a focus on IVDR-relevant process control and audit-ready documentation.
Support with the qualification and auditing of critical suppliers for IVD products—including reagent, antibody, and OEM suppliers. Assessment of IVDR-relevant supplier processes and audit-ready supplier documentation in accordance with ISO 13485.
Preparation for audits as part of the conformity assessment procedure under IVDR Annex IX or Annex XI—including mock audits, document reviews, and preparation of relevant teams for certification audits.
Documented control of regulatory processes, including post-market surveillance, within the quality management system in accordance with ISO 13485 and the IVDR.
Metecon supports diagnostic laboratories with accreditation and IVDR-compliant laboratory operations in accordance with ISO 15189.
ISO 15189 is the international quality standard for medical laboratories and serves as the foundation for accredited laboratory processes in the field of diagnostics.
Preparation for the German Accreditation Body (DAkkS): Gap analysis against ISO 15189, document structure, process descriptions, and a mock audit prior to the official assessment process.
Preparation of IVDR- and ISO 15189-compliant laboratory documentation—including SOPs, process descriptions, and audit-ready quality documentation.
Structured integration of ISO 13485 requirements into an existing ISO 15189 QMS—for laboratories that both develop IVDs and use them in their own laboratories (integrated management system).
Metecon supports diagnostic laboratories with accreditation and IVDR-compliant laboratory operations in accordance with ISO 15189.
Structured literature and review processes as part of audit-ready evaluation and documentation procedures within the IVDR QMS.
Documented testing, approval, and method processes within the framework of structured laboratory and quality processes in accordance with ISO 15189 and the IVDR.
Clinical evidence of the IVD’s performance in the target population—PMPF as an ongoing QMS process for the continuous updating of PER.

Dr. Kirsten Theiling is an experienced expert in quality management and regulatory affairs and serves as Metecon’s Quality Management Representative. Our QM experts focus on the following areas related to QMS and auditing: establishing and optimizing quality management systems in accordance with ISO 13485, ISO 9001, ISO 15189, ISO 17025, and 21 CFR Part 820 (QMSR), integration of MDR/IVDR and MDSAP requirements, internal audits and supplier audits, audit readiness checks, as well as CAPA root cause analysis and effective implementation of corrective actions. Metecon’s quality management experts support manufacturers, laboratories, and other regulated organizations in establishing processes, responsibilities, and documentation in a practical and audit-ready manner.
“A good QMS isn’t one that sits in a file cabinet; it’s one that’s put into practice every day. Our goal is a QMS that fits the organization, reliably integrates requirements, and supports audits not just formally but in substance.”
– Dr. Kirsten Theiling, Expert Quality Management & Regulatory Affairs, QMR, Metecon
The key is to approach the QMS from the organization’s perspective rather than from the standard’s: Which processes are actually in place, who is responsible for them, and which documentation is generated anyway? On this basis, the requirements of ISO 13485, ISO 15189, MDR/IVDR, or MDSAP are integrated into a single structure, rather than being managed in parallel. This results in a QMS that remains practical for day-to-day operations while also being audit-ready. Metecon builds this structure in collaboration with manufacturers, laboratories, and regulated organizations.
Outsourced processes—such as sterilization, manufacturing, testing, or sales activities—are a common focus of audits. The interfaces become practical when responsibilities, handoffs, approvals, and documentation are clearly defined and documented in the QMS, including supplier evaluation and monitoring. It is crucial that the interface functions not only contractually but also in practice. Metecon defines these transitions in a way that ensures they stand up to scrutiny during an audit. Learn more on the V&V Services page.
An audit readiness check reveals the following: Do actual processes align with the standard operating procedures? Is the required documentation actually being generated—and can it be located? Do those responsible understand their processes? Are records maintained consistently? Where descriptions and actual practice diverge, discrepancies arise during the audit. Metecon conducts a structured review prior to the audit and closes any gaps before the Notified Body identifies them.
Typical sources of nonconformities include: unclear responsibilities at process boundaries, missing or incomplete documentation of activities performed, inconsistent document control, changes that cannot be traced, and CAPA actions without proof of effectiveness. Often, the cause lies not in an individual document but in the interaction between processes. Metecon specifically addresses these interfaces to ensure that responsibilities, handoffs, and documentation mesh seamlessly.
Signs include: processes that do not scale with growth, recurring deviations, high manual maintenance effort, and difficulties integrating new markets (e.g., MDSAP, FDA) or new product lines. If the QMS is holding the company back rather than supporting it, a structural overhaul is advisable—not just isolated fixes. Metecon aligns QMS structures with organizational development, growth, and international strategic goals to ensure the system remains sustainable.
If CAPA measures merely address symptoms—such as correcting a document—without addressing the root cause within the process, the same deviations will reoccur in a different form. The root cause lies within the system when multiple deviations stem from the same structural weakness: unclear responsibilities, a lack of process integration, or inconsistent documentation. Metecon thoroughly analyzes the root causes and implements measures that effectively address them at their source. Learn more on the PMS & Vigilance Services page.
Among other things, Metecon supports ISO 13485 (QMS for medical devices and IVDs), ISO 15189 (medical laboratories), ISO 9001 (across all industries), the QMS requirements of the MDR and IVDR, and MDSAP for international markets. In addition, we conduct internal audits, supplier audits, and audit readiness checks. The approach is always the same: translating requirements into a practical, audit-ready structure that fits the organization.
The effort involved depends on several factors: the maturity level and size of the organization, the number and complexity of the processes, the standards and markets to be covered (ISO 13485, ISO 15189, MDSAP, FDA), the extent of outsourced processes, the starting point (new implementation vs. optimization), and the desired level of support: ranging from ad hoc consulting to audit support to the complete implementation of a QMS. Following a free initial consultation, Metecon will provide a transparent quote.
A robust QMS integrates requirements, processes, and evidence rather than managing them in parallel. These 7 interfaces ensure that the QMS is substantively sound.
Start with a free initial consultation on your current QMS situation—for manufacturers, laboratories, and other regulated organizations, tailored to ISO 13485, ISO 15189, MDR/IVDR, QMSR, or MDSAP.
Your contact:
Milan Weiß
Sales Manager
T: +49 621 123469-040
milan.weiss@metecon.de
