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    IVDR Transitional Provisions

    Extended deadlines under Regulation (EU) 2024/1860 allowing legacy IVDs to remain on the market until 2027 to 2029 based on class.

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

    Definition

    Article 110 of the IVDR, as amended by Regulation (EU) 2022/112 and Regulation (EU) 2024/1860, extends transitional deadlines for devices lawfully placed on the market under the IVDD. Class D legacy devices may remain on the market until 31 December 2027, Class C until 31 December 2028, and Class B and Class A sterile until 31 December 2029, provided conditions in Article 110(3) are met (no significant changes, IVDR-compliant PMS/vigilance/registration, written agreement with a notified body by set milestones).
    What the regulation says
    Article 110(3) IVDR requires that during the transition period devices continue to comply with the IVDD, are subject to no significant changes in design or intended purpose, and satisfy IVDR requirements on post-market surveillance, market surveillance, vigilance, registration of economic operators and devices.

    What this means in practice

    The 2024 amendment also introduced a mandatory manufacturer notification via EUDAMED when discontinuing supply of a device that might cause a serious shortage (Article 110a), and made the transitional relief conditional on active progression toward IVDR certification, not passive coasting.

    Examples

    • A manufacturer of a Class C legacy IVD must ensure a written agreement with a Notified Body is in place by 26 May 2026 to qualify for the extended market period until 31 December 2028.
    • A laboratory is still able to use an in vitro diagnostic device for a critical pathogen detection, classified as Class D under IVDR, until December 2027 because the manufacturer is actively progressing towards IVDR certification.
    • Following the extension, a company producing a sterile Class A IVD is now preparing for IVDR compliance by December 2029, provided no significant changes are made to the device and post-market surveillance requirements are met.
    Common pitfalls
    • •Treating the extended deadlines as automatic. Manufacturers must have a signed notified-body agreement by 26 September 2025 for Class D, 26 May 2026 for Class C, and 26 May 2027 for Class B/A sterile.
    • •Missing the Article 110a supply-disruption notice, which is mandatory 6 months in advance.

    Frequently asked questions

    No. Manufacturers must have a signed written agreement with a notified body in place by specific milestone dates, such as 26 September 2025 for Class D and 26 May 2026 for Class C, in order for the extended deadlines in Article 110(3) to apply. Devices without such an agreement by the milestone lose eligibility for the extension.
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    Sources

    3 sources

    Every citation below opens the original document. Each is graded against our source-tier hierarchy so you can see what rests on binding law versus commentary.

    Tier 1Binding law and standards· 1Tier 2Regulator guidance and consensus· 2
    Link health: 1 verified 2 unchecked· last checked 2026-06-20
    EUR-Lex·1MDCG·1European Commission·1
    1. 1
      Regulation (EU) 2024/1860
      Tier 1 Unchecked
      EUR-Lexeur-lex.europa.eu
    2. 2
      MDCG 2022-8 Rev.1 Application of Article 110(3)
      Tier 2 Unchecked
      MDCGhealth.ec.europa.eu
    3. 3
      European Commission - Medical Devices
      Tier 2 Verified
      European Commissionhealth.ec.europa.eu

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