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    Technical Documentation

    The dossier of design, manufacturing, risk, and clinical/performance evidence a manufacturer compiles under MDR/IVDR Annexes II and III to demonstrate conformity.

    Reviewed by Christian Espinosa, Founder, Blue Goat CyberLast reviewed September 19, 2026

    Definition

    Under Regulation (EU) 2017/745 (MDR) and Regulation (EU) 2017/746 (IVDR), technical documentation is the complete evidence file a manufacturer must draw up and keep up to date before placing a device on the market. Annex II requires device description and specification, information supplied by the manufacturer, design and manufacturing information, general safety and performance requirements (GSPR) documentation, benefit-risk analysis and risk management, and product verification and validation data including clinical or performance evaluation. Annex III adds post-market surveillance documentation: the PMS plan, PMS report or periodic safety update report (PSUR), and vigilance data. Notified bodies assess technical documentation directly (Class III, implantables, Class D) or by representative sampling (Class IIa, IIb, most Class B/C IVDs) as part of conformity assessment.
    What the regulation says
    Article 10(4) MDR and Article 10(4) IVDR require manufacturers to draw up and keep technical documentation in accordance with Annexes II and III, updated as necessary, and to make it available to competent authorities for the retention periods set in Article 10(8).

    What this means in practice

    Technical documentation is a living file, not a one-time submission. It must be maintained for at least 10 years after the last device is placed on the market (15 years for implantables) and be available to competent authorities on request. In the US FDA system, the closest functional equivalent is the Design History File under 21 CFR 820.30(j), but the DHF is narrower: it documents that the design was developed per the design control procedure, whereas MDR/IVDR technical documentation additionally bundles GSPR conformity, clinical/performance evidence, and PMS in one structured Annex II/III set.
    Common pitfalls
    • Treating technical documentation as a static submission artifact rather than a document set that must be revised whenever design, intended purpose, or risk classification changes.
    • Organizing content by internal department instead of the Annex II/III structure, which slows notified body review and increases the risk of non-conformities during audits.
    • Omitting the Annex III post-market surveillance report or PSUR, assuming Annex II design evidence alone satisfies the regulation.

    Frequently asked questions

    They overlap heavily but are not identical terms. Technical documentation (Annex II/III) is the evidentiary content; the CE marking dossier is the broader package a notified body reviews, which also includes the quality management system audit results and the EU declaration of conformity.
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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· 3
    Link health: 3 verified· last checked 2026-06-20
    EUR-Lex·2eCFR·1
    1. 1
      Regulation (EU) 2017/745, Annex II and Annex III
      Tier 1 Verified
      EUR-Lexeur-lex.europa.eu
    2. 2
      Regulation (EU) 2017/746, Annex II and Annex III
      Tier 1 Verified
      EUR-Lexeur-lex.europa.eu
    3. 3
      21 CFR 820.30(j) Design History File
      Tier 1 Verified
      eCFRecfr.gov

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