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Risk-Based Approach GAMP 5 · ISO 13485 Part 11 · QMSR · EU & FDA

Risk-Based Software Validation for Medical Devices

We validate computer-based systems as well as process, QM, and tool software using a risk-based approach: The effort is limited to what is truly necessary for the validation documentation—in accordance with ISO 13485, GAMP 5, and FDA computer software assurance (CSA). Lean, audit-ready, and maintained in a validated state.

25+
Years of Regulatory Experience
50+
Compliance Experts
EU + FDA
All from a Single Source
CSA + GAMP 5
Validated on a Risk-Based Approach
What It's All About

Validation with a Sense of Proportion—Lean Instead of a Mountain of Documents

Metecon takes a risk-based approach to the validation of computer-based systems: Instead of generating mountains of documentation, we determine the necessary scope of the validation for each system and the tools to be used, based on risk and usage and in accordance with computer software assurance (CSA), GAMP 5 (2nd Ed.), and ISO 13485. This ensures that process, QM, and tool software remain in a validated state—ready for audits by Notified Bodies and the FDA—and that effort is expended only where it is truly necessary for creating validation records.

Intended for: QM Management / QMR, validation and CSV managers, and the Head of Regulatory Affairs—as well as Quality IT, production/process managers, and executives at smaller manufacturers.

"Software validation rarely fails due to a lack of commitment, but rather due to a lack of focus: We validate in a risk-based manner—effort is directed to where it is truly necessary for validation documentation. This ensures that process, QM, and tool software validation remain streamlined, audit-ready, and manageable."

– Thorsten Stumpf · Principal Expert Software & AI · RAC Devices · Metecon GmbH

CSA & GAMP 5 • ISO 13485 · Part 11 • EU & FDA
Typical Challenges

Three Problems Caused by Traditional CSV

Mountains of documents with no added value

CSV with the wrong priorities ties up resources and delays releases without any discernible improvement in quality.

Unclear Scope of Validation

Which systems and tools need to be validated, and to which extent? This results in audit nonconformities with ISO 13485 clauses 4.1.6, 7.5.6, and 7.6.

Cloud/SaaS Not Under Control

Frequent updates and SaaS releases make it nearly impossible to maintain a validated state.

It's worth making the switch now

The FDA CSA Guidance is final (2025, updated in 2026), and as of February 2026, the QMSR refers to ISO 13485. The uniform, risk-based validation approach is now in place.

Classification at a Glance

What Needs to Be Validated—and to Which Extent

scope, risk-based approach, and regulatory framework—clearly organized

Scope: What Needs to Be Validated?

Software that affects product quality, safety, or the effectiveness of the QMS must be validated; the medical device software itself does not need to be validated.

Process & Production Software

software used in quality management processes and in production (ISO 13485, clause 7.5.6).

Quality Management Software

software that is used in the quality management system (ISO 13485, clause 4.1.6).

Monitoring & Measuring Equipment Software

software that is used for monitoring or measuring (ISO 13485, clause 7.6).

Important for Clarification

  • This refers to non-product software—not medical device software (IEC 62304/82304-1)
  • Triggers include impacts on product quality, data integrity, or QMS effectiveness

Software Validation: A Risk-Based Approach

Software validation requires critical thinking and consideration of software risks in order to produce lean documentation:
Testing what matters—rather than testing every feature of the software in question, even those that are irrelevant.

Critical Thinking

Determine the scope of validation based on the intended purpose and risk, not on the software's full range of functions.

Risk-Based Testing

High testing effort for high risk; low testing effort for lower risk.

Supplier Leverage

Use supplier documentation. Suppliers who provide documentation tailored to your needs reduce the testing burden.

Relevant Fundamentals

  • FDA Computer Software Assurance (final 2025, updated 2026)
  • 21 CFR Part 11
  • GAMP 5 (2nd Ed.): risk-based categories, critical thinking, supplier leverage

Standards & QMSR

Validation is required multiple times in ISO 13485; ISO/TR 80002-2 and GAMP 5 specify concrete procedural models. With the QMSR, the EU and the FDA are moving closer together in terms of regulation.

ISO 13485 & ISO/TR 80002-2

Clauses 4.1.6, 7.5.6, and 7.6 require validation; ISO/TR 80002-2 and AAMI TIR36 provide best practices.

QMSR & Part 11

Since February 2026, 21 CFR Part 820 (QMSR) has referenced ISO 13485:2016—consistent with Part 11.

Relevant Fundamentals

  • ISO 13485:2016 clauses 4.1.6 / 7.5.6 / 7.6 · ISO/TR 80002-2 · AAMI TIR36
  • GAMP 5 (2nd Ed.) · FDA CSA · 21 CFR Part 11 · QMSR (Part 820 → ISO 13485) · Data Integrity (ALCOA+)

Risk-based does not mean negligent

ISO/TR 80002-2 is a best practice standard (not harmonized); audits are conducted against ISO 13485, clauses 4.1.6, 7.5.6, 7.6.

Software Validation Throughout the Product Life Cycle

From inventory to validated status

1

System Inventory

Software used in processes, in quality management, or as a tool (e.g., in product development or product V&V) must be documented.

2

Intended Purpose & Risk

The risk associated with each identified software for the use case must be determined—this determines the scope of validation for the corresponding software.

3

Manufacturer Information

Review and use of supporting documentation provided by the manufacturer.

4

Validation Plan, Testing, and Verification

Scope, test methodology (scripted vs. unscripted), risk-based testing, and transparent documentation of results.

5

Report & Approval

Document validation reports and approvals in an audit-proof manner (ISO 13485, QMSR). Approvals with restrictions are also possible.

6

Changes & Validated Status

Evaluate updates and patches and maintain the system in a validated state. If necessary, perform the checks specified in the validation plan.

Effort where it counts

We focus the depth and documentation - using a risk-based approch - on the key system characteristics and we use supplier documentation—this makes validation streamlined, fast, and still audit-ready.

Why Metecon

Validation Expertise that Meets Industry Benchmarks

Risk-Based Scope

Scope of validation per system according to ISO/TR 80002-2, AAMI TIR 36, and GAMP 5 categories. Lean but robust.

Plans & Reports: Audit-Ready

Validation plans and reports that successfully pass NB and FDA audits (ISO 13485, 21 CFR Part 11).

Supplier Leverage

Make strategic use of supplier documentation—less duplication of dffort, less work.

Tool & Process Validation

Validate test tools, measuring equipment, and processes (ISO 13485, 7.5.6, 7.6) – with clear justification.

EU & FDA from a Single Source

Considering ISO 13485, 4.1.6, 7.5.6, 7.6, and QMSR+Part 11 together—an approach for both markets.

Risk-based According to CSA ISO/TR 80002-2 AAMI TIR36 and GAMP 5

We translate complex regulations into actionable strategies. Our benchmarks are modeled after the strengths of leading providers: lean, risk-based validation, audit-ready documentation, and software/process validation.

Metecon meets these criteria and integrates them with product documentation and quality management.

Overlaps with Software Documentation & QMS

Software validation overlaps with quality management and the software life cycle. We cover these related topics on separate pages and link them together to form a coherent evidence structure.

What We Specifically Offer

Overview of Software Validation Services

GAP Analysis of Existing Validation

Review of existing validations and corresponding SOPs for gaps and suitability. Include a pragmatic roadmap for implementation.

Establishing a Validation Process & SOP

Establishing a streamlined, risk-based software validation process or optimizing an existing one.

System Inventory & Risk-Based Validation Approach

Identifying systems, determining their intended purpose and risks, and defining the scope of validation.

Requirements & Specifications

Clearly specifying the requirements (user/functional requirements) for each system—the foundation for targeted, risk-based testing.

Support for Conducting Software Validation

Validating test tools and measuring equipment software—with audit-ready justification.

Support for Software Change Assessment in the Context of Existing Validation

Risk assessment of the change, approval of the change, and assistance in determining and carrying out the necessary validation.

Workshops & Training Sessions

In-house training courses on CSV, CSA, GAMP 5, ISO/TR 80002-2, AAMI TIR36, and Part 11 for QM, RA, and IT.

Software Validation to Support IVD Products

The same risk-based validation strategy also applies to IVD manufacturers under the IVDR.

Clearly separate from Product Validation

Software validation applies to software that is not part of the medical device. We cover the validation of the medical device software itself on the V&V page.

Delimitation

Software Validation vs. Medical Device Software Validation

Software Validation

validation of non-product software: process, quality management, tooling, and measurement equipment software

Basis:
ISO 13485 clauses 4.1.6/7.5.6/7.6, ISO/TR 80002-2, GAMP 5, FDA CSA, Part 11.

Validation of Medical Device Software

verification and validation of the medical device software itself (IEC 82304-1) and of the product’s technical compliance.

The two are intertwined

Tools used in product development (e.g., testing tools) fall under software validation; testing of the medical device itself is part of V&V. We ensure consistency between these two areas of evidence.

Interfaces

What Software Validation Is Interrelated With

Quality Management

Software validation is a QM discipline defined in ISO 13485 and is an integral part of the QMS.

QualityManagement →

Verification & Validation

delimitation and interface for validating product software

V&V →

Risk Management

risk-based scope of validation, integrated with product risk management (ISO 14971)

Risk Management →

Cybersecurity

data integrity and Part 11 requirements impact security

Cybersecurity →

metecon-thorsten-stumpf

Thorsten Stumpf

Principal Expert Software & AI · RAC Devices · Metecon GmbH

Thorsten Stumpf and the Metecon team implement a risk-based approach to software validation. This covers everything from system inventory and risk assessment to validation plans and testing, through to software release and maintaining the validated state, for both EU and international markets.

Frequently Asked Questions About Software Validation

Which software do I actually need to validate—and which not?

Software must be validated in QM-relevant processes, in production, or when used as a monitoring tool, measuring instrument, or testing tool that affects product quality, data integrity, or the effectiveness of the QMS (ISO 13485, 4.1.6 / 7.5.6 / 7.6). Medical device software itself is validated together with the medical device or as a standalone medical device—see the V&V section and the MDSW section for more details.

How do I determine the risk-based scope of validation (CSA instead of CSV)?

Regarding the intended purpose and risk of the system in its context of use (usually a process context): High risk typically requires more extensive validation, while low risk requires less. Certain regulatory documents (including CSA and GAMP 5) provide the framework—efforts are focused where the software could negatively impact the medical device itself or the associated regulatory activities.

How does the FDA CSA Guidance differ from the traditional CSV?

The FDA computer software assurance (final 2025, updated 2026) outlines a risk-based approach incorporating critical thinking, which, in the FDA’s view, requires the least amount of effort. This allows validation to be tailored to the FDA’s requirements. CSV is also a risk-based approach used in the context of the requirements of ISO 13485.

How do I ensure that systems that have already been validated remain in a validated state after updates?

Through a defined process for releasing software after changes: Software updates are assessed on a risk-based basis prior to release; only the functions affected by the change are retested, and supporting documentation is updated accordingly. This ensures that the system remains in a validated state without having to completely revalidate every release.

How can I use supplier documentation to save time and effort?

By incorporating the software vendor’s development and test documentation into one’s own validation process (supplier leverage). For qualified suppliers, this significantly reduces the company’s own testing effort—CSA and GAMP 5 (2nd Ed.) explicitly provide for this.

What does the QMSR (Part 820 → ISO 13485) mean for my software validation?

Since February 2026, 21 CFR Part 820 (QMSR) has included ISO 13485:2016 by reference. This brings EU and FDA requirements for software validation closer together—a consistent, risk-based approach covers both areas.

How does software validation differ from the V&V of medical device software?

Software validation (CSV/CSA) applies to software that is not the product itself but has an impact in the regulatory context—software used in relevant processes, in essential quality management tasks, or as tools employed in product development, (V&V) or production. The verification and validation of the medical device software itself (IEC 62304, IEC 82304-1) is a separate discipline and is addressed separately.

How much does software validation cost at Metecon?

The effort involved depends on the risk associated with the systems in the intended application area, as well as on existing evidence supporting their safe and effective use (EU/FDA). During a free initial consultation, we will assess your case, prioritize it based on risk, and then provide a robust framework.

Implementing Lean Software Validation

Start with a free initial consultation. We’ll then prioritize based on risk, review supplier documentation, and outline your audit-ready validation approach. We turn complexity into clarity.

Your contact:

Milan Weiß
Sales Manager
T: +49 621 123469-040
milan.weiss@metecon.de

milan-weiss-ansprechpartner-sales-metecon