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Software & AI [Software Lifecycle](/ecosystems/software-lifecycle)SiMD  /sim-dee/ 

# Software in a Medical Device

Software embedded in or required to operate a hardware medical device.

Reviewed by [Christian Espinosa, Founder, Blue Goat Cyber](/authors/christian-espinosa) Last reviewed May 5, 2026 

## Definition

Software in a Medical Device (SiMD) refers to software that is embedded within, or required for, the operation of a hardware medical device - such as firmware controlling an infusion pump or imaging system. 

What the regulation says

Software in a Medical Device (SiMD) is considered a component of a hardware medical device and is regulated as such, rather than as a standalone medical device. The FDA addresses this in its guidance on " [Software as a Medical Device](/terms/samd) (SaMD): Clinical Evaluation," clarifying that SiMD falls under the regulatory framework of the device it enables. Similarly, under the  [EU Medical Device Regulation](/terms/mdr) (EU  [MDR](/terms/mdr-reporting)) 2017/745, SiMD is subject to the  [general safety and performance requirements](/terms/gspr) (GSPRs) applicable to the overall medical device, as outlined in Annex I. 

## What this means in practice

Unlike  [SaMD](/terms/samd), SiMD is regulated as part of the parent device. It is still subject to  [IEC 62304](/terms/iec-62304), cybersecurity requirements, and  [design controls](/terms/design-controls). 

## Examples

-   Firmware that controls the delivery mechanism and dosage calculations of an insulin pump is an example of SiMD.
-   Software embedded in an MRI machine that processes imaging data and controls the scanner's operations is considered SiMD.
-   The operating system and user interface software on a patient monitor that displays vital signs is an instance of SiMD.

Common pitfalls

-   • Failing to integrate SiMD development and maintenance into the overall medical device's lifecycle management processes can lead to regulatory non-compliance. 
-   • Overlooking the specific cybersecurity risks associated with integrated software can compromise the safety and effectiveness of the medical device. 
-   • Treating SiMD with less rigor than standalone software regarding design controls and validation activities is a common mistake. 
-   • Assuming that general software development practices are sufficient without adapting them to medical device regulations is a pitfall. 
-   • Neglecting to update SiMD in response to new cybersecurity threats or operating system changes can lead to vulnerabilities and regulatory issues. 

## Frequently asked questions

How does SiMD differ from Software as a Medical Device (SaMD)? 

SiMD is integral to the functioning of a hardware medical device and is regulated as part of that device.  [SaMD](/terms/samd), in contrast, is software that itself constitutes a medical device and performs a medical function without being part of a hardware medical device. 

Is SiMD subject to IEC 62304? 

Does SiMD need to comply with cybersecurity regulations? 

## Cross-references

### Governed by

Regulations or standards this term must comply with.

-   [
    
    IEC 62304
    
    
    
    ](/terms/iec-62304)

### Often confused with

Distinct concept frequently mistaken for this one.

-   [
    
    Software as a Medical Device(SaMD) 
    
    SaMD is standalone software; SiMD is software inside a device.
    
    
    
    ](/terms/samd)

## Related terms

Grouped by theme 

### Editor's picks

· Hand-selected related concepts 

[

Software & AI

Software as a Medical Device(SaMD) 

Software intended for medical purposes that performs without being part of a hardware device.





](/terms/samd)[

Standards

IEC 62304

Lifecycle requirements for medical device software.





](/terms/iec-62304)

### SaMD & AI/ML Devices

· From this learning path 

[

Software & AI

Clinical Decision Support(CDS) 

Software providing healthcare professionals with knowledge and patient-specific information.





](/terms/cds?from=samd-and-ai)[

Software & AI

Predetermined Change Control Plan(PCCP) 

FDA mechanism to pre-authorize specific modifications to AI/ML-enabled devices.





](/terms/ai-ml-pccp?from=samd-and-ai)[

Software & AI

Software of Unknown Provenance(SOUP) 

Software not developed for medical device use, or lacking adequate development records, incorporated into a device.





](/terms/soup?from=samd-and-ai)[

Software & AI

Software Safety Classification

IEC 62304 classes A, B, C reflecting potential harm from software failure.





](/terms/software-safety-class?from=samd-and-ai)

### Software Team Onboarding

· From this learning path 

[

Cybersecurity

Section 524B of the FD&C Act(524B) 

The federal statute that gives FDA explicit premarket authority over cybersecurity for cyber devices.





](/terms/section-524b?from=software-team-onboarding)[

Cybersecurity

Secure Product Development Framework(SPDF) 

A documented, risk-based set of processes that build cybersecurity into a medical device across its full lifecycle.





](/terms/spdf?from=software-team-onboarding)[

Cybersecurity

Software Bill of Materials(SBOM) 

A machine-readable inventory of all software components, including open-source and third-party libraries, used to build a medical device.





](/terms/sbom?from=software-team-onboarding)[

Cybersecurity

Threat Modeling

A structured analysis that identifies how an attacker could compromise a medical device and what controls mitigate each threat.





](/terms/threat-modeling?from=software-team-onboarding)

Cited by

Where this term appears across MedTech Terms.

Learning paths (2)

-   [SaMD & AI/ML Devices](/paths/samd-and-ai)Lesson 2 of 9 
-   [Software Team Onboarding](/paths/software-team-onboarding)Lesson 2 of 12 

Ecosystems (1)

-   [Software Lifecycle](/ecosystems/software-lifecycle)

Comparisons (1)

-   [SaMD vs SiMD](/compare/samd-vs-simd)vs Software as a Medical Device 

## Primary references

3 sources 

Link health:  3 verified · last checked 2026-06-20 

FDA· 2 IMDRF· 1 

1.  [1 
    
    FDA Software Functions
    
    Verified 
    
    FDA · fda.gov 
    
    
    
    ](https://www.fda.gov/medical-devices/digital-health-center-excellence/device-software-functions-including-mobile-medical-applications)
2.  [2 
    
    FDA - AI/ML-Enabled Medical Devices
    
    Verified 
    
    FDA · fda.gov 
    
    
    
    ](https://www.fda.gov/medical-devices/software-medical-device-samd/artificial-intelligence-and-machine-learning-aiml-enabled-medical-devices)
3.  [3 
    
    IMDRF - Software as a Medical Device
    
    Verified 
    
    IMDRF · imdrf.org 
    
    
    
    ](https://www.imdrf.org/working-groups/software-medical-device-samd)

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

Sponsor note

### Building software-as-a-medical-device?

We help SaMD and AI/ML device teams meet IEC 62304 and the FDA's evolving expectations for software cybersecurity.

[Book a 30-minute discovery session](https://go.bluegoatcyber.com/meetings/blue-goat-cyber/discovery-session)

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MedTech Terms is a community resource sponsored by [Blue Goat Cyber](https://bluegoatcyber.com). Definitions are independent of any vendor.

On this term

Category

Software & AI

Acronym

SiMD

Sources

3

Updated

5/5/2026

[Compare with another term](/compare?a=simd)

Learn in 60 seconds

Card Lesson Quiz

Software embedded in or required to operate a hardware medical device.

-   · Unlike SaMD, SiMD is regulated as part of the parent device. 
-   · It is still subject to IEC 62304, cybersecurity requirements, and design controls. 

Remember this

Watch out: Failing to integrate SiMD development and maintenance into the overall medical device's lifecycle management processes can lead to regulatory non-compliance.

Related terms

-   [Software as a Medical Device(SaMD) ](/terms/samd)
-   [IEC 62304 ](/terms/iec-62304)

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Related resources and services on this topic.

-   [
    
    AI SaMD Insights 
    
    How AI is changing SaMD - risk, regulation, and good machine-learning practice.
    
    ](https://ai-samd.com)
-   [
    
    Med Device Cyber Podcast 
    
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    ](https://mdcpodcast.com)

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Resources

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