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MDR and IVDR Regulatory Writing

Medical Device and IVD Regulatory Writing for Manufacturers

Pubrica prepares the clinical, performance and post-market documentation that medical device and IVD manufacturers need under EU MDR and IVDR. Under MDR and IVDR, evaluation is continuous: a plan precedes each report, post-market data feeds back into both, and the state of the art must be re-established at each update. Our device and IVD regulatory writers prepare all twelve documents in the order the regulations expect, from clinical and performance evaluation plans and reports to PMCF, PMS, device PSUR, SSCP, risk management and technical file documentation.

  • Plan before report, because a clinical evaluation report without an approved CEP is a common and predictable notified body deficiency
  • Documented state of the art, supported by a reproducible search, as the benchmark against which every claim is judged
  • Post-market obligations set by class: PSUR annually for IIb and III, at least every two years for IIa, a PMS report for class I under Article 85
  • IVDR documents prepared separately, covering performance evaluation, scientific validity and analytical and clinical performance rather than an adapted clinical evaluation
  • MDCG guidance applied, including 2019-9 rev 1 for SSCP and 2020-13 for the assessment report template your file will be read against
Common Deficiencies in Device Files Frequently raised findings

CER without an approved planRaised first

State of the art not documentedSecond most common

Equivalence claimed without full evidenceRarely accepted

PMCF treated as optionalRequires justification

GSPR checklist without evidence referencesChecked line by line

Plan → evaluation → report → post-market → back into the plan

Applied across every file
  • The regulation and MDCG version named in the document
  • Plan written and approved before the report
  • Search protocol behind every state-of-the-art claim
  • Post-market obligations set by class, not by habit
  • Written to the assessor’s template
Twelve documentsMDR and IVDR, plan through post-market
ISO 14155:2026Replaced the withdrawn 2020 edition
MDCG 2020-13The assessment report template
ISO 9001:2015Quality management certified · cert. H3CR9TCU20251212INDQM10N

Deliverables

Twelve MDR and IVDR Documents in Regulatory Sequence

The documents follow the sequence the regulation sets. A report dated before the plan it is meant to follow is a finding in itself.

Clinical evaluation plan The CEP, prepared before the CER, setting out the intended purpose, claims to be substantiated, state-of-the-art method, acceptance criteria and clinical development route.

MDR Annex XIV, firstMost serious CER deficiencies trace back to a plan that was written afterwards or not at all.

Clinical evaluation report The evaluation itself, appraising and analysing clinical data against the acceptance criteria the plan set, with the benefit-risk conclusion evidenced.

Against the plan’s criteriaA favourable conclusion against criteria set after the evidence was reviewed does not constitute an evaluation.

State-of-the-art review The documented benchmark: current alternatives, accepted performance and known risks, with a reproducible search behind it.

The benchmark for everything elseThe state of the art is not a literature summary. It is the standard the device must meet or exceed.

Performance evaluation plan The IVDR equivalent: scientific validity, analytical performance and clinical performance planned as three separate demonstrations.

IVDR Annex XIIIThese are three separate demonstrations. Combining them is the most common structural error under IVDR.

Scientific validity report The evidence that the analyte is associated with the clinical condition at all — established independently of your device’s performance.

Before your device is mentionedScientific validity concerns the biomarker, not the assay, and evidence for one is not evidence for the other.

Performance evaluation report The three strands brought together against the plan, with the intended purpose and the claimed clinical benefit both evidenced.

The IVDR conclusionAn assay can perform well analytically and still lack clinical usefulness, so the report addresses both.

PMCF plan & report Post-market clinical follow-up planned as a study or justified as unnecessary — and the justification has to be evidenced too.

Or an evidenced justification“PMCF not applicable” without a documented rationale is a finding in its own right.

PMS & device PSUR The surveillance plan and the periodic reports, at the frequency your class actually sets rather than the one the template assumed.

Frequency set by classClass IIb and III devices require a PSUR annually, class IIa at least every two years, and class I a PMS report under Article 85. We set the reporting frequency for your device class.

SSCP The public-facing summary for class III and implantables, in both the professional and the patient version, to MDCG 2019-9 rev 1.

Two audiences, one documentThe patient version is written and validated separately, because it is read by people making decisions about their own treatment.

Device risk management file The ISO 14971 file kept consistent with the clinical evaluation, so risk control and clinical benefit are telling the same story.

ISO 14971, reconciledAssessors read the risk file and the CER together, so any inconsistency between them is identified quickly.

GSPR checklist Annex I worked through requirement by requirement, each one pointing at the document and section that actually demonstrates it.

Each requirement linked to its evidenceA checklist that cites a document not containing the evidence is treated more seriously than a gap.

Technical file & 510(k) The US route: substantial equivalence argued against a predicate, with the comparison structured the way the review actually runs.

For the FDA routeThe choice of predicate largely determines the strength of the submission, so we assess it first.

The samples shown are illustrative and anonymised. Hover over a sample to replay it.

Compliance and Standards

Four Device Regulatory Standards at Current Versions

Device standards are revised regularly. A file built on a withdrawn edition may have to be corrected at the notified body’s request, so we work to current versions.

2017/745

MDR and IVDR (the regulations themselves)

Annex XIV for clinical evaluation and PMCF, Annex XIII for performance evaluation, Articles 83 to 86 for surveillance and periodic reporting.

14155:2026

ISO 14155:2026 (clinical investigation of devices)

The 2026 edition replaced the withdrawn 2020 edition on 23 March 2026. Protocols written to the 2020 edition need to be reconciled with it rather than reissued.

14971

ISO 14971 (risk management)

The risk file is read alongside the clinical evaluation, and both must state the same benefit and residual risk.

ISO9001:2015

Quality management (cert. H3CR9TCU20251212INDQM10N)

Our certified quality system governs how work is run, recorded and released.

Responsible Use of AI

Our Approach to AI Use in Medical Device Regulatory Writing

Regulatory reviewers trace decisions back to evidence and to named individuals. For this reason, source traceability takes priority over speed whenever we use AI tools.

How We Use AI ToolsWe use AI tools to find source material across a document set, to check the consistency of terms, figures and cross-references between documents, and to draft highly templated sections that a writer then verifies line by line against source.
Where We Do Not Use AIWe do not use AI for unverified text entering a submission, clinical or benefit-risk interpretation, safety narratives, literature appraisal for a clinical evaluation, or any statement an assessor would expect to trace to a named, qualified individual.
Your AI Use DeclarationYour declaration states the tool used, the stage at which it was used and the human oversight applied. Journals, funders, regulators and the ICMJE January 2026 update now expect this, and an undeclared tool found later is treated as an integrity matter.

Why We Do Not Publish AI Accuracy Figures

Accuracy figures for AI tools are usually reported by the companies that sell them.

Pubrica therefore does not quote its own accuracy figure, which would carry the same conflict of interest. Instead, we tell you which tool was used on your project, at which stage, and what a specialist changed afterwards.

Our Process

How We Develop Your Medical Device File

The regulation sets the order of the work, so the four steps follow a fixed sequence.

Step one

Classification and Scoping

Device class, conformity route and regulation determine which of the twelve documents you need and how often each must be updated.

Step two

Clinical or Performance Evaluation Plan

We prepare the CEP or PEP with acceptance criteria specific enough that the device could fail to meet them.

Step three

State-of-the-Art Assessment

We document a reproducible search to establish the benchmark against which the rest of the file is judged.

Step four

Evaluation, Reporting and Post-Market Feedback

We prepare the report against the plan, then feed PMS and PMCF data into the next revision, because the regulations require a continuous cycle.

Our Experts

Your Medical Device Regulatory Writing Team

A named team of subject specialists stays with your project from scoping to delivery. Your project coordinator introduces each team member by name before work begins.

Subject matter expertClinical or scientific expert matched to your topic

Reviews the scientific content for accuracy and confirms that each conclusion is supported by the evidence. Each expert is matched to your field of research.

OwnsScientific accuracy and interpretation
Reviews againstICMJE, COPE and the applicable reporting guideline
FieldMatched to your topic
Medical writerDrafts the document to the applicable guideline

Writes the manuscript or document against the applicable reporting guideline and the target journal or funder requirements, with every statement traceable to its source.

OwnsDrafting and source traceability
Reviews againstICMJE and the applicable reporting guideline
OutputSubmission-ready draft
BiostatisticianStatistical input where the work reports analysed data

Checks that statistical methods, tables and conclusions are consistent with the analysis plan and that the analysis can be reproduced.

OwnsStatistical accuracy
Reviews againstICH E9 and the statistical analysis plan
ToolsR, SAS, Stata, Python
Second reviewerIndependent quality check before delivery

Checks the finished work independently against the agreed scope and the applicable checklist. Findings are logged and resolved before delivery.

OwnsIndependent quality control
Reviews againstThe agreed scope and checklist
Signed off byProject lead

FAQs

Medical Device and IVD Regulatory Writing FAQs

If your question is not answered here, ask an expert. No quote is required.

This is the most common serious finding we see. It cannot be corrected by backdating the plan, and we do not backdate documents.

The appropriate route is to write the plan now, with the current date, and run the next evaluation against it, disclosing the gap. Assessors handle this situation regularly.

Under MDR this requires technical, biological and clinical equivalence together, plus a contract giving you full access to their technical documentation. In practice that last condition rules it out for most manufacturers.

We advise early on whether your equivalence argument is likely to be accepted, before the file is built around it.

We prepare documents and support your responses, but correspondence with the notified body remains yours, because it is assessing your quality system and your file.

The teams overlap but are not identical. Device work is assigned to writers who work with MDR and IVDR routinely, because the frameworks differ in structure as well as terminology.

Related Services

Related Regulatory Writing Services

Services that provide evidence for a device file, and services that use the completed file.

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