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    AI Act Conformity Assessment (Medical Devices)

    For AI-enabled medical devices, AI Act requirements are assessed through the MDR/IVDR notified-body procedure, not a separate CE route.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed July 25, 2026

    Definition

    Article 43(3) provides that where an AI system is a safety component of, or is itself, a product covered by Annex I legislation such as the MDR or IVDR, the AI Act requirements are checked as part of the conformity assessment procedure under that legislation. The notified body performing the MDR/IVDR assessment therefore extends its scope to cover the relevant AI Act articles.

    What this means in practice

    Practically, manufacturers must ensure their notified body is designated for the AI Act scope relevant to the device. Technical documentation under MDR Annex II or IVDR Annex II must be extended to include the AI Act Annex IV elements (data governance, training methodology, evaluation, cybersecurity, human oversight).
    Common pitfalls
    • Selecting a notified body designated only under MDR without confirming AI Act scope designation.
    • Duplicating documentation instead of integrating AI Act evidence into the existing technical file.
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    Primary references

    3 sources
    Link health: 3 verified· last checked 2026-06-20
    EUR-Lex·1RAPS·1FDA·1
    1. 1
      Regulation (EU) 2024/1689, Article 43
      Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      RAPS Regulatory Focus
      Verified
      RAPSraps.org
    3. 3
      FDA - Medical Devices
      Verified
      FDAfda.gov

    Inline markers like [1] jump to the matching reference above.