The AI Act will take effect in August 2027
High-risk AI must comply with the AI Act starting in August 2027. MDCG 2025-6 governs the interaction with the MDR/IVDR. Those who start planning early and in a structured manner gain planning certainty.
AI in medical devices is not a traditional software project; rather, it requires an appropriate process framework. We consistently integrate the software life cycle, data strategy, risks, and evidence—embedded within the QMS and technical documentation rather than managed in parallel—ensuring that changes are controllable and the necessary evidence is generated.
Metecon supports manufacturers throughout the entire software life cycle: from regulatory categorization and classification, through architecture, data strategy, and risk management, to verification, validation, and post-market surveillance. We prioritize decision-relevant requirements early on, ensure clear interfaces with software development, cybersecurity, risk management, and technical documentation, and keep changes and further developments under control. The goal is to create robust AI processes that are operationally feasible—traceable during audits and maintainable throughout the product life cycle.
Intended for: Heads of Regulatory Affairs / Regulatory Leads and Heads of Software / Development Managers, as well as executives at SaMD manufacturers with AI-driven product strategies and Quality Management Leaders.
AI systems are being developed, but regulatory requirements are coming too late—resulting in rework and delays.
Interfaces between development, quality management, and regulatory affairs are unclear—documentation is created in isolation and is inconsistent across departments.
Requirements are considered separately. Regulatory requirements are not implemented. The necessary supporting documentation is not available, and the resulting changes are extremely time-consuming.
High-risk AI must comply with the AI Act starting in August 2027. MDCG 2025-6 governs the interaction with the MDR/IVDR. Those who start planning early and in a structured manner gain planning certainty.
The AI Act and MDR/IVDR apply in parallel. We clearly classify your product and integrate the requirements of both frameworks into a consistent documentation structure.
If the AI itself is a medical device (or safety component) and a Notified Body is involved in the conformity assessment, it is considered high-risk AI. This typically applies to MDR class IIa+ or IVD class B+. The AI Act classification does not change the MDR class—the regulatory frameworks build upon one another.
Procedure for classification under article 6 of the AI Act.
Integrate AI Act requirements into the existing QMS and technical documentation; do not create duplicate systems.
Practical implementation of transparency and human oversight requirements (AI Act, Art. 14).
The data strategy determines the capabilities of the resulting AI:
The origin, quality, representativeness, and traceability of the data form the basis for any demonstration of the AI’s validity for its intended purpose.
document training, test, and validation data in a traceable manner, including evidence of the data's independence
conduct of verification and validation of the AI function in a robust and traceable manner
structured assessment of risks arising from data quality and model behavior (ISO 14971 + ISO/IEC 23894)
The EU and the FDA pursue similar goals through different approaches. The FDA focuses on integrating the requirements into the existing regulatory framework. With the AI Act, the EU is pursuing its own regulatory framework for AI, which is harmonized with other laws such as the MDR/IVDR.
Define planned model changes in advance so that predictable changes can be made without the need for re-approval.
Realistically assess the benefits and limitations for your own QMS: not harmonized, generic. We prevent duplicate effort.
The AI Act classification does not change the MDR class. AI Act requirements must be integrated into the existing QMS and technical documentation. ISO/IEC 42001 helps with the integration of AI-specific requirements into the existing process landscape.
According to Article 6 of the AI Act and MDCG 2025-6, AI in a medical device is considered high-risk AI if both of the following conditions are met:
Is the AI software itself a medical device or a safety component of one?
Is a Notified Body involved in the conformity assessment (typically MDR class IIa and higher / IVD class B and higher)?
If both apply: The AI Act and MDR/IVDR apply in parallel, integrated into the QMS and technical documentation.
regulatory categorization of AI software and classification (MDCG 2019-11), including high-risk assessment
The backbone of robust AI: software architecture and a traceable data life cycle for training, test, and validation data. The foundation for any future verification.
assessment of data, model, and change risks (ISO 14971 + ISO/IEC 23894), ensurance of transparency and human oversight, implementation of appropriate measures to ensure the safe use of AI in the product or as a product
provision of robust evidence of AI performance and traceability
keeping model, data, and architecture changes under control via a predetermined change control plan
systematic incorporation of market data into evaluation, model maintenance, and further development
The origin, quality, traceability, and timeliness of the data determine the validity of the AI.
use-case analysis and classification in accordance with the AI Act and MDCG 2025-6, with clearly defined actions
reliable, traceable data processes for training, validation, and updates, to serve as regulatory evidence
predetermined change control plan and significant change assessment, changes are manageable rather than risky
an AI-based management system with a sense of proportion: clear benefits and limitations, no duplicate effort required for ISO 13485 compliance
Consider the AI Act and FDA GMLP/PCCP together. Develop requirements once and use them for both markets.
Part of the Metecon Group: 25+ years of regulatory experience, 50+ compliance experts, and offices in Mannheim (Germany) and Bern (Switzerland). We translate complex regulations into feasible strategies.
Our benchmarks are based on the strengths of leading providers: the substantive mapping of regulatory requirements by specialized knowledge centers, PCCP/change control approaches, and AI governance tools. Metecon meets these criteria and combines them with end-to-end implementation "from a single source", embedded within the MDSW documentation framework (link).
AI is not a standalone feature, but rather part of the software life cycle. We cover medical device software (MDSW), cybersecurity, and software validation on separate pages. They are linked here as a cohesive reference structure.
Review of existing documentation and processes for gaps in compliance with the AI Act, MDR/IVDR, and standards, with a concrete roadmap.
Technical Documentation →
Clear definition of intended purpose and classification: the basis for high-risk classification and scope.
In-house workshops on product definition, classification, and AI requirements for development, quality management, and regulatory affairs.
Workshops & Training →
Preparation and support in interactions with Notified Bodies and regulatory authorities—reliable and consistent.
For AI governance, monitoring, and change control, we integrate specialized tools and partners as needed, incorporating them into your documentation structure.
The same regulatory framework for AI also applies under the IVDR to software for, in, and as an IVD.
IVD Software →
We first clarify the requirements that are relevant to the decision. This prevents the need for rework and ensures that AI products can be planned, approved, and maintained.
AI is part of the software life cycle. Unambiguously classify SaMD, embedded or MDSW.
AI systems are vulnerable to manipulation, data poisoning, and model attacks.
Systematically assess and keep up to date data, model, and change risks, as well as risks posed by AI itself (ISO 14971).
Consistently document model descriptions, development decisions, and supporting evidence.
Robust evidence of the performance and traceability of AI in or as a medical device.
Market data influences valuation and further development; this is systematically factored in.

Thorsten Stumpf is an expert in RAC Devices and software—and is extremely well-connected within the industry on this topic. His team assists manufacturers with the regulatory classification of AI-based medical devices within the complex interplay of the MDR, IVDR, and AI Act. It also provides support in classifying, documenting, and translating AI system characteristics into regulatory-compliant arguments.
EU AI Act & MDCG 2025-6 • Data Strategy & PCCP • EU & FDA“AI in medical devices is not an isolated software project. It requires a process landscape in which the software life cycle, data strategy, risk management, and regulatory documentation work together consistently. It is crucial to integrate these requirements into the quality management system and the technical documentation from the very beginning. This is the only way to manage changes in a controlled manner and generate the necessary evidence in a reliable way."
– Thorsten Stumpf, Principal Expert, Software & AI · RAC Devices · Metecon GmbH
As early as possible: starting with the concept and architectural phases. By structuring classification, data strategy, and risks early on, you can avoid rework and keep costly changes under control later on.
Through a predetermined change control plan (PCCP) and a significant-change assessment: Planned changes and their limits are defined and documented in advance, so that not every foreseeable adjustment triggers a new conformity assessment.
It is robust when classification, data strategy, risk management, V&V, and PMS are consistently linked, and AI is integrated into all processes and documented in a traceable manner. Isolated evidence for aspects of AI is a red flag.
Risks arising from the training data used and model behavior (ISO 14971 + ISO/IEC 23894) determine which characteristics must be demonstrated. V&V verifies the implementation and effectiveness of measures to ensure the safe use of AI systems. This is consistent with risk management and data strategy.
One key factor: The origin, quality, representativeness, and traceability of the data determine the performance of AI systems. Sound data governance is a prerequisite for an AI system to reliably deliver the promised performance in the context of medical devices.
Through a closed-loop process: Post-market data regarding the AI system are collected in a structured manner, evaluated against expectations and risks, and incorporated into model maintenance, change management, and, if necessary, a new conformity assessment.
In addition to the life cycle activities specified in IEC 62304, there are also activities related to AI-specific requirements: data strategy, model behavior and robustness, transparency, and human oversight; and—for high-risk AI—the requirements of the AI Act in addition to the MDR/IVDR.
Article 4 of the AI Act requires that individuals who provide or operate AI systems possess sufficient AI expertise. For manufacturers, this means providing verifiable training for the teams involved. We provide support through workshops and product-specific certifications. We clearly delineate data protection aspects (e.g., GDPR Article 9 regarding health data) in this process.
The effort involved depends on the product, AI system, risk, data availability, and target markets (EU/U.S.). During a free initial consultation, we'll assess your case, review the high-risk classification, and then provide a reliable framework.
Start with a free initial consultation. We’ll assess the high-risk classification, determine compliance with the AI Act and MDR/IVDR, and outline your AI documentation structure. Complexity is then transformed into clarity—reliably, efficiently, and always one step ahead.
Your contact:
Milan Weiß
Sales Manager
T: +49 621 123469-040
milan.weiss@metecon.de
