You develop connected medical devices, software as a medical device or in vitro diagnostics, or you supply electronics and firmware for them. The MDR and IVDR require cybersecurity across the entire life cycle. Complass guides you from the threat model to reporting in the field.
Notified bodies check Annex I sections 17.2 and 17.4 MDR. If the threat model, security risk file or SBOM is missing, the conformity assessment is delayed.
Vulnerabilities across the entire lifetime
Operating systems and libraries age faster than a medical device. You have to detect, assess and if necessary report new vulnerabilities in the field.
Suppliers deliver too little
Without SBOMs, security information and update commitments from suppliers, your own documentation remains incomplete.
What the MDR and IVDR require
The requirements apply per product, before and after placing on the market. The main points:
Develop software according to the state of the art, with risk management that includes information security Annex I section 17.2 MDRAnnex I Section 17.2 MDRFor devices that incorporate software or for software that are devices in themselves, the software shall be developed and manufactured in accordance with the state of the art taking into account the principles of development life cycle, risk management, including information security, verification and validation.As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 19.07.2026Open original (EUR-Lex – consolidated version of 19.07.2026) ↗
Set out minimum requirements for hardware, IT networks and IT security measures that the operator must meet Annex I section 17.4 MDRAnnex I Section 17.4 MDRManufacturers shall set out minimum requirements concerning hardware, IT networks characteristics and IT security measures, including protection against unauthorised access, necessary to run the software as intended.As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 19.07.2026Open original (EUR-Lex – consolidated version of 19.07.2026) ↗
Monitor products after placing on the market, including for new vulnerabilities Art. 83 MDRArticle 83 MDRPost-market surveillance system of the manufacturer1. For each device, manufacturers shall plan, establish, document, implement, maintain and update a post-market surveillance system in a manner that is proportionate to the risk class and appropriate for the type of device. That system shall be an integral part of the manufacturer's quality management system referred to in Article 10(9). 2. The post-market surveillance system shall be suited to actively and …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 19.07.2026Open original (EUR-Lex – consolidated version of 19.07.2026) ↗
Report serious incidents and field safety corrective actions Art. 87 MDRArticle 87 MDRReporting of serious incidents and field safety corrective actions1. Manufacturers of devices made available on the Union market, other than investigational devices, shall report, to the relevant competent authorities, in accordance with Articles 92(5) and (7), the following: - (a) any serious incident involving devices made available on the Union market, except expected side-effects which are clearly documented in the product information and quantified in the technical …As of: 05.10.2026 · Source: EUR-Lex – consolidated version of 19.07.2026Open original (EUR-Lex – consolidated version of 19.07.2026) ↗
Manufacturers of medical devices of medium size or larger are additionally important entities under NIS2 Section 28 BSIG and Annex 2§ 28 BSIGBesonders wichtige Einrichtungen und wichtige Einrichtungen(1) Als besonders wichtige Einrichtung gelten - 1. Betreiber kritischer Anlagen, - 2. qualifizierte Vertrauensdiensteanbieter, Top Level Domain Name Registries oder DNS-Diensteanbieter, - 3. Anbieter öffentlich zugänglicher Telekommunikationsdienste oder Betreiber öffentlicher Telekommunikationsnetze, die - a) mindestens 50 Mitarbeiter beschäftigen oder - b) einen Jahresumsatz und eine Jahresbilanzsumme von jeweils …As of: 26.09.2026 · Source: gesetze-im-internet.deOpen original (gesetze-im-internet.de) ↗
No CRA for medical devices. Medical devices and in vitro diagnostics are excluded from the Cyber Resilience Act (Art. 2(2) CRA). Components that you also sell outside medical technology, however, generally fall under the CRA. Go to the page for manufacturers
General information, not legal advice. This page summarises the legal position in simplified form and does not replace an assessment of your individual case. The wording of the laws and standards is authoritative.
Typical companies
Connected medical equipment
Devices with network connection, remote maintenance or radio module, from infusion pumps to imaging systems.
Software as a medical device
Standalone software and apps with a medical intended purpose, often with a cloud component.
In vitro diagnostics
Analysers and laboratory software under the IVDR, with the same requirements for software and the IT environment.
Suppliers to the medical technology industry
Electronics, embedded software and contract manufacturing: your customers pass the requirements on to you.
How Complass helps
MDR and IVDR in seven phases
From classification through secure development and technical documentation to surveillance, vigilance and a dedicated phase for suppliers.
The medical technology industry template preselects the framework for the MDR and IVDR and the building blocks you need for the threat model, vulnerabilities and suppliers.
available
Industry template: Medical technology
Cybersecurity for medical devices under the MDR and IVDR
Vulnerabilities and SBOM
Risk management
MITRE ATT&CK for the threat model
Supplier Management
from €476 per month plus VAT in the Start package, size S, annual payment
All prices are for businesses, not for consumers. They are net plus VAT with annual payment; monthly payment carries a surcharge of 15 %. As of 16 October 2026. Enterprise and groups of companies on request.
Frequently asked questions
Why not simply the package for manufacturers?+
The package for manufacturers is geared to the Cyber Resilience Act. Medical devices are excluded from it and are subject to the MDR and IVDR instead. The medical technology package is therefore built on the framework for medical devices.
Hospitals ask us about IT security when purchasing. What helps?+
Hospitals increasingly expect an SBOM, the minimum requirements for the IT environment and commitments on updates. You maintain this information per product in Complass and keep it up to date for tenders.
Does NIS2 also apply to medical device manufacturers?+
Yes, from medium size onwards, because the manufacture of medical devices and in vitro diagnostics is listed in Annex 2 of the German BSI Act. NIS2 then concerns your company, the MDR and IVDR your products. Complass handles both in the same account.