Regulated software has two jobs: work, and prove it worked.
Medical device software, computer system validation and data integrity — engineered for GxP environments and designed to answer an inspector years after release, not just pass user acceptance testing.
Compliance built in costs less than compliance retrofitted
Teams that treat regulatory work as a post-launch cleanup rewrite their architecture, their test
evidence, or both. The traceability an auditor asks for — requirement to design to test to release — cannot
be reconstructed convincingly after the fact, because the artefacts that would prove it were never created
in the right order. We build it in from the first architecture decision.
Traceability artefacts cannot be convincingly reconstructed after the fact. Teams that leave it until after release pay for the rewrite.
Four practices
Medical device software development, IEC 62304
End-to-end development for software as a medical device and software in a device: safety classification
and its consequences for the process, architecture and detailed design, SOUP and third-party component
management, unit and integration verification, and the software part of the technical file. Risk management
runs under ISO 14971 throughout rather than as a document produced at the end, and usability engineering is
carried alongside it because most software hazards are use hazards.
Computer system validation, GAMP 5 and CSA
Validation of GxP systems — EDC, eCOA, RTSM, LIMS, eTMF, QMS, ERP and clinical platforms — under GAMP 5,
21 CFR Part 11 and EU GMP Annex 11 — and, for clinical trials, the EMA guideline on computerised systems and electronic data. Risk-based and right-sized: critical thinking applied to where the patient
risk and data integrity risk actually sit, testing effort concentrated there, and unscripted testing used
where it is the better evidence. We also transition organisations from traditional CSV to a computer
software assurance approach without leaving a validation gap in the handover.
The V draws, then the traceability links close it.
Data integrity and ALCOA+
Data integrity programmes for clinical, laboratory and manufacturing environments: audit trail design and
audit trail review that someone actually performs, electronic signature workflows, access and segregation
controls, data lifecycle and retention, and remediation where integrity has already been compromised. The
hard part is rarely the system — it is the manual steps and spreadsheets between systems, and that is where
we look first.
Cloud, SaaS and legacy modernisation
Vendor and supplier qualification for SaaS platforms where you validate what you cannot inspect, shared
responsibility models made explicit, validated migration from on-premise to cloud with compliance
continuity, and modernisation of legacy GxP systems that are past support but still hold regulated
records.
Validated systems are rarely the problem. The manual steps and spreadsheets between them are where ALCOA+ fails.
Software at the edge of the trial
Validation practice was built for systems in a controlled data centre. A study today runs on software
executing on a participant's own phone, over a network you do not control, against an operating system that
updates without asking. The controls still apply; the evidence has to be gathered differently. Perimeters
two and five of our assessment — computerised systems and configuration change — are where that is worked
out, and it is the reason our validation work and our device work are the same practice rather than two
teams.
Software that is itself a device
Where the software is the medical device, the two halves meet: IEC 62304 governs how it is built, the
device perimeter governs whether it needed to be built that way, and an AI-enabled function adds a change
control question on top of both. We run those together rather than sequentially, because discovering the
qualification answer after the architecture is set is the most expensive order to do it in.
The AI Act is a conformity problem, not a policy problem
Teams treat the EU AI Act as governance paperwork. For an AI-enabled medical device it is a second
conformity route running alongside EU MDR, with its own technical documentation, risk management, data
governance, logging, transparency, human oversight and post-market monitoring duties. These are checked within the EU MDR or IVDR conformity assessment, by a notified body that must also meet the AI Act’s requirements for assessing AI systems (AI Act Art. 43(3)).
Whether it applies to you turns on two cumulative conditions, not one. Article 6(1)
makes an AI system high-risk where it is a safety component of, or is itself, a product covered by Annex I
harmonisation legislation — Section A of which lists EU MDR 2017/745 at item 11 and IVDR 2017/746 at
item 12 — and where that product requires third-party conformity assessment. A self-certified Class I
device does not satisfy the second condition. A Class IIa device with a notified body does.
The date. The AI Act has applied generally since 2 August 2026. For Annex I products — which include devices under EU MDR 2017/745 and IVDR 2017/746 — the high-risk obligations under Article 6(1) apply from 2 August 2028, the date set by the AI Omnibus, Regulation (EU) 2026/1744, in force since 27 July 2026. Nothing about that date is generous: an AI-enabled device in development now has to carry its AI Act technical documentation, risk management, data governance and post-market monitoring in the file it is already writing.
What we do about it. Applicability determination that survives challenge in either
direction. Gap assessment of the AI Act duties against what your ISO 13485 and IEC 62304 processes already
produce — which is more than most teams expect, and the overlap is where the budget is saved. Change
control for models that keep learning, aligned with the change control plan you need for the device
anyway. And the documentation set built once, mapped to both regimes, rather than twice.
How we work with your teams and vendors
Validation and data integrity fail when they are treated as a vendor handover. We sit with
your IT quality lead, your eClinical vendor and your statistics group to define:
Intended use in the protocol — what the software is allowed to do in this
study, not what the marketing brochure claims.
Validation boundary — what is in scope for CSV/CSA, what is vendor-owned,
and what is bridged with evidence rather than re-tested.
Change ownership — who approves an app update, an OS patch or a model
retrain, and what record proves the validated state still holds.
The output is a validation pack and a change-control path that survives vendor turnover —
because the reasoning is in your system, not in a consultant's laptop.
Doing this across a whole operation, not one system?
Digital Transformation of Clinical Operations applies the
same controls — validation, data integrity, change control and inspection readiness — to every DHT,
eClinical system and data flow at once, in five gated phases.
Two papers behind this service
A free account opens both — no approval step, no sales call attached.
A companion reading from the device-management vendor seat — what the control plane must evidence, and when constraining a device is someone else’s regulatory problem
When a device captures trial data — a handset, a wearable, a home instrument or the gateway that relays them — attribution, time and protection against alteration are decided on the device, and no validated database can decide them later.