V&V According to the MDR vs. the IVDR: Differences at a Glance
Both regulations require verification and validation—with different areas of focus. For IVDs, there are additional requirements regarding the performance evaluation.
Many V&V programs result in an enormous testing burden and still leave gaps because requirements, risks, and evidence are not consistently linked. We structure your verification and validation in a risk-based manner and ensure that requirements, risks, tests, and results are fully traceable—anchored in technical documentation and the QMS, without overengineering and without gaps.
25+ years of experience · 300+ V&V projects · accredited laboratory networkVerification and validation are distinct but inextricably linked mandatory activities under the MDR and IVDR.
Verification and validation are not simply a matter of running through a series of isolated tests. We translate requirements and risks into a risk-based test strategy with verifiable acceptance criteria and consolidate the results in such a way that every requirement and every risk remains fully traceable all the way through to verification—anchored in technical documentation and the QMS, without overengineering and without gaps.
Feedback: Product changes, revalidation activities, and post-market findings are incorporated in a controlled manner while maintaining traceability.
Instead of treating tests merely as isolated tasks, we coordinate test strategy, execution, and documented evidence management from a single source: Risks determine the depth of testing, acceptance criteria are defined in advance, and the traceability matrix links requirements, risks, tests, and results in a consistent manner—even for software (IEC 62304), usability, and AI systems.
Verification & Validation at Metecon
“V&V with consistent traceability – requirements, risks, and evidence linked in a traceable manner.”
Either a significant effort with no gain in insight, or gaps that will require rework later on.
For you: We determine the scope of testing and priorities based on risks and acceptance criteria—in a targeted manner rather than a one-size-fits-all approach.
Requirements and risks are not consistently linked to tests and results.
For you: We build a comprehensive traceability matrix that ensures changes can be evaluated in a controlled manner.
Unplanned but necessary measures prolong development and increase costs.
For you: We plan verification and validation (V&V) early on to avoid late rework and schedule risks.
The V-Model is a well-established development and testing model for medical devices and software.
In regulatory projects, it is used in particular in connection with IEC 62304 and IEC 60601-1.
Stakeholder Requirements
What the user needs (intended purpose)
Traceability
Validation
Summative usability, clinical performance
System Requirements
What the product must be able to do
System Tests
Verify integration into the overall product
Software Requirements
Functional and non-functional software requirements
Integration Tests
Interaction between software modules
Component Design
Detailed design of modules and units
Unit Tests
Testing individual software components
Verification checks whether requirements are met.
Validation checks whether the product fulfills its purpose.
Both regulations require verification and validation—with different areas of focus. For IVDs, there are additional requirements regarding the performance evaluation.
| Criterion | Medical Devices (MDR) | In-Vitro Diagnostic Medical Devices (IVDR) |
| Legal Basis | MDR (EU) 2017/745 Annex I (GSPR) + Annexes II/III | IVDR (EU) 2017/746 Annex I (GSPR) + Annex XIII |
| Standards Framework | MDR: IEC 62304, IEC 60601-1, and other product-specific testing standards | IVDR: IVDR Annex XIII (SVR, APR, CPR), ISO 20916, CLSI EP documents |
| V-Model / Process | product-specific tests (mechanical, biological, and electrical safety, sterility, etc.) | analytical performance evaluation (APR) + clinical performance study (CPR) |
| Software | IEC 62304 mandatory + IEC 82304-1 for standalone software | IEC 62304 applies to IVD software |
| External laboratories | biocompatibility, EMC, electrical safety, sterility (DAkkS/ISO 17025) | analytical validation, clinical performance studies (ISO 20916) |
| Process validation | validation of relevant manufacturing processes | analytical method validation |
| Key guideline | MDCG 2020-1 (software) | MDCG 2022-2 (performance evaluation) |
| Transition periods |
MDR is in effect—current recertifications are underway | class D through 2027 · class C through 2028 · class B and A (sterile) through 2029 |
risk-based scope of testing, GSPR mapping, selection of standards (IEC 62304, IEC 60601-1, etc.), V&V concept, and detailed test specifications
unit tests, integration tests, and system tests in accordance with IEC 62304; supplemented by IEC 82304-1 as needed
accredited laboratory network (DAkkS, ISO 17025): biocompatibility, EMC, electrical safety, sterility-full coordination
all three IVDR performance evaluation pillars: scientific validity, analytical performance (CLSI), and clinical performance (ISO 20916)
Verification and validation demonstrate that medical devices meet the defined requirements for safety, performance, and their intended purpose. Metecon supports manufacturers in the planning, coordination, and documentation of regulatory-relevant testing and evaluation activities in accordance with the MDR.
The general safety and performance requirements (GSPR) set forth in MDR Annex I must be demonstrated through V&V activities—for all classes I through III.
systematic V&V design: risk-based scope of testing, GSPR mapping, selection of standards (IEC 62304, IEC 60601-1, ISO 10993, etc.), and testing strategy for internal and external testing.
full traceability of requirements, tests, and results—documented in a transparent manner and consistent with the V&V strategy.
development of test specifications that comply with standards (test cases, test steps, acceptance criteria) and traceable test reports with an evaluation of results.
impact analysis for product changes: Which tests need to be repeated or supplemented? A risk-based re-testing approach to avoid unnecessary repeat testing.
short-term support for V&V gaps, additional requirements, and incomplete test documentation—practical and compliant with regulatory requirements.
If preclinical data and existing evidence are insufficient, clinical trials in accordance with Article 62 of the MDR may be required. Metecon provides support with regulatory classification and integration into the V&V strategy.
IEC 62304 requires structured testing at the unit, integration, and system levels—supplemented by IEC 82304-1 for standalone software. Metecon systematically addresses these gaps.
IEC 62304 defines the mandatory test activities depending on the software safety class (A, B, C): unit tests (components), integration tests (modules), and software system tests (entire system). According to Amendment 1 (2015), software system tests are mandatory for all classes. Metecon plans, designs, and documents all required test activities—in compliance with standards and suitable for Notified Bodies. ISO 14971 measures regarding software are verified, regardless of the safety class.
Software as a Medical Device (SaMD) is additionally subject to IEC 82304-1 for health software. Metecon provides support for validation in accordance with MDCG 2020-1 and for demonstrating clinical performance for SaMD products.
ISO 13485 clause 4.1.6 requires the validation of QMS software. Metecon creates CSV plans, CSV decision matrices, and IQ/OQ/PQ protocols for ERP, eQMS, LIMS, and production software.
IEC 81001-5-1 and MDCG 2019-16: security testing (penetration testing, SBOM analysis) as part of software V&V activities. Integration into the technical documentation in accordance with MDR Annex II.
AI-based software classified as a medical device imposes additional requirements for verification, validation, and performance monitoring. Metecon takes current regulatory requirements such as MDCG 2020-1 and the EU AI Act into account in the V&V context.
Laboratory bottlenecks can delay approval by months. Metecon coordinates your entire external testing program—selection, scheduling, sample management, and results evaluation—all from a single source.
Metecon does not operate as a laboratory—we coordinate. Our network of accredited testing institutes (DAkkS, ILAC members, ISO 17025) covers all key testing areas:
Laboratory selection · Technical coordination of test specifications · Sample and equipment coordination · Interface management · Regulatory interpretation of results · Structured provision of test reports for V&V documentation.
Coordination of regulatory-relevant testing in accordance with ISO 10993 at accredited testing laboratories.
IEC 60601-1-2 (EMC), IEC 60601-1 (Electrical Safety), IEC 60601-1-11 (home healthcare environment): test planning, laboratory selection, and integration of results in TechDoc.
Validation of sterilization and packaging processes is performed in accordance with relevant standards, depending on the product, packaging system, and intended purpose. Metecon provides support with test coordination and the documentation of regulatory evidence.
Only DAkkS-accredited laboratories or those accepted as equivalent (ILAC members). Biocompatibility testing is conducted exclusively in GLP-certified laboratories. Metecon verifies the scope and validity of accreditation prior to placing an order.
Coordination of mechanical and physical tests: for example, compressive strength, fatigue tests, protection class (IP rating) according to IEC 60529, drop tests, vibration, and environmental testing.
ISO 13485 clause 7.5.6 requires the validation of all processes whose results cannot be, or are not, fully verified through subsequent monitoring.
Mandatory validation for processes without complete verification of results: sterilization, coating, welding, filling of sterile products, bonding. IQ/OQ/PQ protocols, statistical validation approaches.
ISO 13485 clause 4.1.6: Validation of all QMS-relevant software tools; 7.5.6 Process validation for manufacturing; 7.6 Software validation for monitoring and measuring equipment; CSV Decision Matrix; IQ/OQ/PQ for eQMS, ERP, LIMS, PLM. GAMP 5 principles as a reference. Metecon creates the complete CSV plan and provides support during implementation.
Support for summative usability evaluations in accordance with IEC 62366-1, including test planning, execution, and integration of the results into the V&V documentation.
IVDR Annex XIII defines requirements for scientific, analytical, and clinical performance evidence. Metecon provides support for the planning, coordination, and documentation of this evidence in accordance with MDCG 2022-2.
Extended transition periods apply to certain IVDR legacy devices under defined conditions. Evidence of compliance should be prepared well in advance.
The pieces of evidence complement each other depending on the product type, intended purpose, and risk class.
Scientific performance data support the demonstration of the medical and diagnostic relevance of an IVD in its intended context of use.
Analytical performance studies evaluate the technical performance parameters and reliability of an IVD under defined test conditions.
Clinical performance data support the demonstration of an IVD’s diagnostic performance in the intended target population.
Protocol-based literature search in medical databases (PubMed, EMBASE, etc.) to demonstrate the analyte-status relationship. Assessment of data quality, currency, and relevance according to MDCG 2022-2 requirements. Fully documented for the PER.
Complete SVR in the MDCG 2022-2-compliant format: description of the analyte, target population, diagnostic question, literature summary, state of the art, assessment of scientific validity, and conclusion.
Existing scientific evidence can be updated with new literature and post-market surveillance data.
CLSI EP protocols are the internationally recognized standard for analytical performance studies. CLSI-compliant APR reports make it easier to demonstrate compliance with the state of the art.
Metecon provides support for the planning, coordination, and regulatory documentation of analytical performance testing in accordance with CLSI EP protocols.
Determine LOD & LOQ
Limit of detection (LOD) and limit of quantitation (LOQ)—determined precisely according to the CLSI protocol for each matrix.
Precision (Repeatability & Reproducibility)
Intra-laboratory precision and inter-laboratory precision according to CLSI EP5: repeatability, within-lab precision.
Comparison of Methods & Accuracy
Comparison of test method vs. reference method: systematic deviations, proportionality errors.
Linearity & Measurement Range
Verification of the linear measurement range and analytical measurement interval (AMI) according to CLSI EP6.
Interferences & Cross-Reactivities
Systematic testing for potential interfering substances (hemoglobin, bilirubin, lipids, etc.) and cross-reactivities.
Shelf Life & Stability
Reagent shelf life under various storage conditions – required for IVDR compliance.
If APR and literature data are insufficient, a clinical performance study conducted in accordance with ISO 20916 provides the necessary evidence. Metecon provides support for the regulatory planning, design, and classification of clinical performance studies in accordance with ISO 20916.
Evidence of diagnostic performance in the target population: clinical sensitivity and specificity (vs. the reference standard), predictive values (PPV/NPV at realistic prevalence), ROC curve analysis. Fully documented in the clinical performance report (CPR) in accordance with IVDR Annex XIII 1.2.3.
Support in planning clinical performance studies in accordance with ISO 20916, including study design and data analysis strategy.
Support with regulatory requirements for clinical performance studies, including ethics committee and regulatory agency processes.
Coordination of regulatory-related processes in the context of clinical performance studies.
Support for the analysis and documentation of clinical performance data in a regulatory context.
Post-market surveillance data can supplement and update existing performance data.
Notified bodies evaluate PER documents against MDCG 2022-2. Metecon Standard: All SVR, APR, and CPR reports are prepared in accordance with MDCG 2022-2.
MDCG 2022-2, “Guidance on general principles of clinical evidence for IVDs,” specifies the IVDR requirements for SVR, APR, and CPR from a NB perspective: acceptable data sources, distribution of the burden of proof by risk class, and minimum requirements for literature data and studies.
Class A: literature data is usually sufficient. Class B/C: literature data is often supplemented by proprietary studies. Class D: literature data, proprietary studies, involvement of EU reference laboratories. Metecon is familiar with the NS expectations for each class.
Peer-reviewed literature, routine diagnostic data, proprietary performance studies (ISO 20916), registry data, post-market data. Metecon evaluates your existing data and identifies gaps—before you undertake a costly study.
Performance evidence must be structured in a traceable manner and documented consistently.

Julian Raum is a seasoned Metecon expert specializing in the verification and validation of medical devices. Since 2016, he has been supporting projects from the derivation of regulatory, normative, and product-specific requirements through the development of suitable test strategies to the execution and documentation of verification and validation. Our V&V team’s focus: to consistently link requirements, risks, tests, and results, and to ensure that the necessary traceability is consistently reflected in the technical documentation and the quality management system.
"Requirements, risks, and evidence clearly and traceably linked—together with you, we’ll develop the verification and validation (V&V) strategy that’s right for you, with consistent traceability."
– Julian Raum, Expert Regulatory Affairs & Technical Documentation, Metecon

Dr. Sandra Reuter leads the IVD team at Metecon and has more than 20 years of experience in the development and regulatory evaluation of in-vitro diagnostic medical devices, including several years as a regulatory affairs manager in the industry. Together with her team, she supports manufacturers in planning, conducting, and documenting verification and validation activities for IVDs. A key focus is on analytical performance studies and the consistent alignment of performance requirements, study design, results, and performance evaluation.
"Performance studies provide reliable evidence only if performance requirements, study design, acceptance criteria, and evaluation are consistently aligned. It is precisely this alignment that must subsequently be reflected in the performance assessment."
– Dr. Sandra Reuter, Team Lead IVD, Metecon
Verification checks whether a product meets the specified requirements (e.g., Does the defibrillator deliver 3,000 V?). Validation verifies whether the product fulfills its intended purpose and meets the needs of users in the target environment (e.g., Is the heart beating after use?). Together—V&V—they are mandatory components of the technical documentation according to MDR Annex I and IVDR Annex I.
The V-Model is the reference model for structured medical device development in accordance with IEC 62304 and IEC 60601-1. The left side describes the requirement levels (from stakeholder requirements to component design), while the right side describes the corresponding test activities (from unit tests to validation). Each requirement has a direct test activity. Traceability between requirements and tests is mandatory.
IEC 62304 governs the software lifecycle for medical devices and IVDs. Software validation includes unit tests (components), integration tests (modules), and system tests (entire system). According to Amendment 1 (2015), system tests are mandatory for all safety classes. IEC 82304-1 provides additional requirements for standalone medical device software (SaMD). CSV in accordance with ISO 13485 Section 4.1.6 applies to the QMS infrastructure.
IVDR Annex XIII defines three types of mandatory evidence:
1) Scientific validity (SVR): Relationship between analyte and medical condition based on a literature review.
2) Analytical performance (APR): Technical parameters such as LOD/LOQ, sensitivity, specificity, and precision, e.g. according to CLSI protocols.
3) Clinical performance (CPR): Diagnostic performance in the target population, if applicable, through a clinical performance study in accordance with ISO 20916.
ISO 20916 (good clinicalpPractice for clinical performance studies) is the standard for the planning, conduct, and documentation of clinical performance studies for IVDs. A dedicated study is required if there are insufficient literature data, routine diagnostic data, or historical data to demonstrate clinical performance. Metecon prepares the clinical performance study plan (CPSP) and coordinates the ethics committee approval and study conduct.
MDCG 2022-2 is the EU’s key guideline on the performance evaluation of IVDs under the IVDR. It specifies the NB’s expectations regarding SVR, APR, and CPR: the distribution of the burden of proof by risk class, acceptable data sources, minimum requirements, and the PER structure. All Metecon performance evaluation reports are based on MDCG 2022-2.
The test strategy (V&V concept) defines the overall testing approach: applicable standards, test methods, risk classes, scope of testing, and internal vs. external testing. The V&V plan specifies these details for a specific product: concrete test cases, test specifications, and acceptance criteria.
CLSI (Clinical and Laboratory Standards Institute) EP protocols are the international standards for analytical IVD validation: EP17 (LOD/LOQ), EP5 (precision), EP9 (interlaboratory comparison), EP6 (linearity), EP7 (Interferences). Notified bodies expect CLSI-compliant APR reports make it easier to demonstrate compliance with the state of the art.
Accredited testing laboratories (DAkkS in Germany, ILAC members internationally) conduct tests in accordance with ISO 17025, such as biocompatibility (ISO 10993), EMC (IEC 60601-1-2), electrical safety (IEC 60601-1), and sterilization (ISO 11135/11137). Therefore, laboratories that can demonstrate this accreditation for the relevant test methods are generally suitable. Metecon coordinates the selection of laboratories, manages interfaces, and integrates laboratory reports into the technical documentation.
Risk Management
ISO 14971 – Risk Management for MDR & IVDR
TechDoc
Technical Documentation for MDR & IVDR
Usability
Usability Engineering IEC 62366-1
Clinical Affairs
CER, PMCF, PER, and PMPF
QMS
QMS & ISO 13485 Auditing
Software
Software & Cybersecurity (IEC 62304)
Biocompatibility
Biological Safety ISO 10993
PMS
Post-Market Surveillance (MDR)
Start with a free initial consultation on your V&V situation. We’ll provide you with a transparent cost estimate in no time.
Your contact:
Milan Weiß
Sales Manager
T: +49 621 123469-040
milan.weiss@metecon.de
