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    IEC 62304

    Lifecycle requirements for medical device software.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed May 5, 2026

    Definition

    IEC 62304:2006 (with Amendment 1:2015) defines the lifecycle requirements for medical device software, including software development planning, requirements analysis, architectural design, implementation, integration, testing, release, and maintenance - scaled by software safety classification (Class A, B, C).

    What this means in practice

    IEC 62304 is a recognized consensus standard by FDA and a harmonized standard under EU MDR. It is foundational for SaMD and software-containing devices. The standard scales its expectations by software safety class: Class A (no injury possible) requires the lightest process, Class B (non-serious injury) adds detailed design and integration testing, and Class C (death or serious injury) adds unit testing, more rigorous architecture, and stronger SOUP controls.

    Examples

    • A Class C infusion pump control application with unit tests, formal architectural design records, and full SOUP evaluation for the RTOS and TLS stack.
    • A Class B mobile SaMD dose calculator with documented software requirements, integration tests, and a maintained anomaly list.

    Use cases

    1 scenario
    1

    Legacy infusion pump firmware refresh

    Software lead

    A team refactoring 10-year-old C firmware classifies the safety class as C, retrofits a software development plan, traces requirements to unit tests, and documents SOUP for the RTOS and TCP/IP stack.

    OutcomeThe refresh ships with full IEC 62304 evidence, satisfying both 510(k) reviewers and an EU MDR notified body.
    Common pitfalls
    • Under-classifying software to avoid Class C obligations. Auditors and reviewers actively challenge classifications that do not align with the device's hazard analysis.
    • Skipping SOUP (Software of Unknown Provenance) requirements for open-source libraries and third-party components.
    • Treating IEC 62304 as an alternative to ISO 14971. It complements risk management; it does not replace it.
    • Losing traceability between software requirements, architecture items, unit tests, and integration tests.

    Frequently asked questions

    Class A: no injury or damage to health is possible. Class B: non-serious injury is possible. Class C: death or serious injury is possible. The class is set based on the hazard analysis and may be reduced by external risk controls (hardware safeguards, alarms, procedural controls).

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    Primary references

    3 sources
    Link health: 2 verified 1 unchecked· last checked 2026-06-20
    ISO·1FDA·1IEC·1
    1. 1
      IEC 62304:2006/AMD1:2015
      Verified
      ISOiso.org
    2. 2
      FDA Recognized Consensus Standards
      Unchecked
      FDAaccessdata.fda.gov
    3. 3
      IEC Webstore - Medical Equipment
      Verified
      IECwebstore.iec.ch

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