Global AI Initiative Database

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Proposed Regulatory Framework for Modifications to AI/ML-Based Software as a Medical Device


Added by:   National contact point
Added on:   09 Jul 2025
Updated by:   OECD analyst
Updated on:   09 Jul 2025

The Food and Drug Administration (FDA) is considering a total product lifecycle-based regulatory framework for AI/ML technologies that would allow for modifications to be made from real-world learning and adaptation, while still ensuring that the safety and effectiveness of the software as a medical device is maintained.

Name in original language

Proposed Regulatory Framework for Modifications to AI/ML-Based Software as a Medical Device

Initiative overview

The FDA's traditional paradigm of medical device regulation was not designed for adaptive AI and ML technologies. Under the FDA's current approach to software modifications, the FDA anticipates that many of these AI and ML-driven software changes to a device may need a pre-market review.The initiative has the following objective(s):To seek public comment on a discussion paper that describes the FDA's foundation for a potential approach to pre-market review for AI/ML-driven software modifications.

Name of responsible organisation (in English)

Food and Drug Administration (FDA)

About the policy initiative


Organisation:

  • Food and Drug Administration (FDA)

Category:

  • National – AI policy initiatives, regulations, guidelines, standards and programmes or projects

Initiative type:

  • Principles/guidelines/frameworks for trustworthy AI

Participating organisations:


Participating countries:


Status:

  • Inactive – initiative complete

Start Year:

  • 2019

Binding:

  • Non-binding

Other relevant urls: