FDA 21 CFR Part 11 / SaMD — taught, not scanned
Updated 2026-05-15What this is
21 CFR Part 11 sets requirements for trustworthy electronic records and signatures in FDA-regulated contexts: validation, audit trails, authority checks, and signature integrity. Software as a Medical Device (SaMD) adds intended-use and risk-classification obligations.
Why an AI-generated app in this domain must care
If a tool influences a clinical decision or holds regulated electronic records, its regulatory burden is set by intended use and risk class, which drive validation and quality-system obligations far beyond application security.
Why PreFlight does not scan for FDA rules
Part 11 and SaMD conformance is established through validation documentation, a quality management system, risk files, and intended-use statements. A static code scan cannot evaluate validation status or intended use, so PreFlight maps no probe to FDA rules.
Generic security probes still apply to the software as security findings, and an audit trail being absent in code may be relevant evidence, but PreFlight does not present these as Part 11 conclusions.
What a reviewer looks for
A validation plan and results, controlled audit trails, signature manifest integrity, and a risk classification consistent with intended use. These are documentation and process artifacts.
Not legal advice
This page explains why FDA software rules are out of scan scope. It is not regulatory advice. Engage regulatory affairs and quality professionals.