EUDAMED Fully Functional EU Sets 2026 Deadline

On 27 November 2025, European Commission formally declared that four core modules of EUDAMED — Actor Registration, UDI/Device Registration, Notified Bodies & Certificates, and Market Surveillance have met their functional specifications. As a result, a six‑month transition period begins, making these modules mandatory from 28 May 2026.
Why This Is a Big Deal
End to “voluntary use” era: Until now, many companies used EUDAMED voluntarily or relied on national registries. From May 2026 onward, all responsible economic operators (manufacturers, authorised representatives, importers, Notified Bodies) must register and use these modules under MDR 2017/745 (and where applicable, IVDR 2017/746).
Broader traceability and transparency: EUDAMED becomes the centralised system for device registration, UDI assignment, certificates, and market‑surveillance oversight. This strengthens regulatory oversight and harmonises device data across the EU.
Fixed deadlines for legacy and new devices: New MDR/IVDR devices placed on the EU market after 28 May 2026 must be registered in EUDAMED beforehand. Legacy devices (already on the market) must be registered by 28 November 2026.
Certificate and Notified‑Body data compliance window: For devices certified prior to mandatory EUDAMED use, Notified Bodies must upload certificates and associated documentation (e.g. Master SSPs) extended until 28 May 2027.
Key Risks & Challenges for Manufacturers / IVD Companies
Compliance burden & resource readiness: Many companies (especially smaller ones) will need to rapidly audit their internal device registries, generate UDI codes if not yet assigned, ensure valid certificates, and map their supply‑chain and post‑market surveillance data to comply with EUDAMED.
Legacy device catch‑up pressure: For devices already on the market, failure to register by the November 2026 deadline may risk non-compliance potentially leading to market access issues or regulatory enforcement.
Notified Bodies / certification backlog risk: Notified Bodies must integrate into EUDAMED and upload all pre-existing certificates but given historically slow timelines for full EUDAMED deployment (especially clinical & vigilance modules), there may be backlog or resource constraints.
What This Means for Non‑EU Manufacturers & Global Regulatory Strategies (e.g. India‑based companies)
Global supply‑chain alignment required: Manufacturers outside the EU including India targeting EU markets must align with EUDAMED timelines. This increases the need for robust regulatory planning and early data generation.
Proactive MDR/IVDR dossier alignment becomes critical: Device dossiers for EU submission must now be conceived with EUDAMED registration in mind including UDI allocation, certificate uploading, and readiness for post‑market surveillance obligations.
Read more in detail here: EU Confirms EUDAMED Functionality With May 2026 Deadline Set
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