QMS / cGMP Support

Medical device quality management system documentation for FDA QMSR and ISO 13485 compliance
FDA Medical Device QMSR / cGMP Support

Medical Device QMSR / cGMP Support

Quality-system support for covered medical-device manufacturers under FDA's current Quality Management System Regulation — including QMSR gap assessments, ISO 13485:2016 alignment, documentation, CAPA, risk-based quality processes, and inspection readiness.

Direct answer: FDA's QMSR became effective February 2, 2026. It amended 21 CFR Part 820 by incorporating ISO 13485:2016 and FDA-specific requirements. QMSR generally applies to finished device manufacturers, subject to device-specific exemptions. ISO 13485 certification alone is not FDA certification and does not automatically establish QMSR compliance.
Contact Us for PricingCustom quote · Scope tailored to your facility and QMS needs
1,000+Clients Served
135+Countries Served
2013Serving Clients Since
2026QMSR Effective
Foreign & Domestic Manufacturers
21 CFR Part 820 / QMSR
ISO 13485:2016 Alignment
Inspection Readiness Support

What Is QMSR / cGMP Support & Who Must Comply?

FDA's Quality Management System Regulation is the current device CGMP framework in 21 CFR Part 820. Effective February 2, 2026, it incorporates ISO 13485:2016 by reference and adds FDA-specific requirements and definitions. The rule is designed to harmonize FDA's medical-device quality-system framework with internationally recognized quality-management principles while preserving FDA's statutory and regulatory authority.

QMSR applies to finished device manufacturers that intend to commercially distribute medical devices. Certain device-specific CGMP exemptions exist, so the correct compliance scope depends on the device, activity, and classification regulation rather than a blanket rule that every company selling a device has identical Part 820 obligations.

  • QMSR became effective February 2, 2026.
  • ISO 13485:2016 is incorporated by reference into the current Part 820 framework.
  • FDA-specific requirements still apply even when a company holds ISO 13485 certification.
  • Device-specific CGMP exemptions should be checked before defining the compliance scope.
  • FDA replaced the former QSIT inspection approach with Compliance Program 7382.850.

Our Medical Device QMSR / cGMP Support Services

Our QMSR support covers the core areas manufacturers need to assess, document, implement, and maintain a compliant medical-device quality management system.

Service 01

QMSR Gap Assessment

Review your current quality system against applicable QMSR, ISO 13485:2016, and FDA-specific requirements to identify documentation, implementation, training, risk-management, and record-control gaps.

Service 02

ISO 13485 Alignment & Implementation Support

Support alignment of procedures and operational controls with ISO 13485:2016 as incorporated into QMSR, while separately addressing FDA-specific requirements that are not satisfied merely by holding a third-party ISO certificate.

Service 03

Quality Documentation & CAPA Support

Assist with applicable procedures and records covering document control, supplier controls, complaints, CAPA, training, management review, internal audits, risk-based quality activities, and other quality-system processes.

Service 04

FDA Inspection Readiness

Prepare for FDA's current QMSR inspection process through document review, mock-inspection activities, record-readiness checks, response planning, and remediation support without guaranteeing an inspection outcome.

Medical Device QMSR Compliance Support Built for the Current FDA Framework

Key service and regulatory milestones that reflect our international reach and the current FDA quality-system framework.

1,000+Clients Served

FDA compliance support across regulated industries and international markets.

135+Countries Served

Support for foreign and U.S. companies entering or operating in the U.S. market.

2013Serving Clients Since

Established regulatory-support experience for companies navigating FDA requirements.

2026QMSR Effective

FDA's QMSR and new device-manufacturer inspection process took effect February 2, 2026.

How Our Medical Device QMSR / cGMP Support Service Works

A structured four-step process to assess the quality system, prioritize gaps, support implementation, and prepare for FDA oversight.

1

Initial QMS Assessment

Provide current procedures, records, organization details, device scope, manufacturing activities, and any ISO 13485 certification or prior audit information relevant to the engagement.

2

Compliance Roadmap

We identify applicable gaps and prioritize documentation, risk-management, CAPA, supplier, training, audit, management-review, and implementation actions based on your actual operations.

3

Implementation Support

We support development and implementation of the applicable procedures, records, controls, remediation activities, and internal responsibilities required by the agreed project scope.

4

Inspection Readiness & Ongoing Support

We perform mock-review and readiness activities, help organize inspection records, identify unresolved issues, and provide continuing support as procedures or operations change.

What Changed Under QMSR in 2026?

These points are especially important for quality teams still using pre-2026 QSR terminology or inspection assumptions.

ISO 13485:2016 Incorporated

QMSR incorporates ISO 13485:2016 as the foundational quality-management framework, together with FDA-specific requirements and the controlling provisions of the FD&C Act and other FDA regulations.

QSIT Discontinued

FDA stopped using the former Quality System Inspection Technique on February 2, 2026 and moved to the inspection process in Compliance Program 7382.850.

More Audit Records Can Be Reviewed

FDA states that management-review, quality-audit, and supplier-audit reports no longer have the prior Part 820.180(c) inspection exception and may be reviewed by FDA investigators.

CGMP Exemptions Still Matter

Some devices are exempt from certain CGMP requirements by classification regulation. Exemption must be checked device by device and does not necessarily remove every complaint or record obligation.

Important: QMSR compliance is an ongoing manufacturing-quality obligation. It is separate from establishment registration, device listing, UDI, labeling, MDR, and premarket authorization requirements that may also apply.

Complete FDA Medical Device Compliance Solutions

Related FDA medical-device services for establishment registration, listing, labeling, U.S. Agent representation, quality systems, renewals, laser reporting, and import compliance.

Medical Device Establishment Registration

FDA establishment registration and annual review support for applicable domestic and foreign medical-device facilities.

Medical Device Listing

Device listing support with classification and product-code review for applicable devices associated with registered establishments.

Medical Device Labeling & Product Review

Review labels, packaging, IFU, UDI/GUDID considerations, and applicable FDA device-labeling requirements.

Medical Device DUNS Request Assistance

DUNS request and verification support for FDA medical-device registration, GUDID, and related CDRH workflows.

Medical Device U.S. Agent Services

Annual U.S. Agent representation for applicable foreign medical-device establishments and FDA communications.

Medical Device Listing Certificate

Professional verification document prepared from applicable FDA registration and listing records; not FDA-issued.

QMSR / cGMP Support

Gap assessment, ISO 13485 alignment, documentation, CAPA, mock-inspection, and ongoing quality-system support.

Medical Device Annual Establishment Renewal

Annual FDA registration review and renewal coordination, including linked registration and listing maintenance.

Import Alert & Device Detention Resolution

Case-specific support for FDA device detentions, Import Alerts, corrective actions, and entry-compliance issues.

Laser Accession Report & Submission

Prepare the FDA Laser Product Report / Radiation Safety Product Report, coordinate CDRH submission, and follow the accession number for applicable laser products.

Frequently Asked Questions — Medical Device QMSR / cGMP Support

Current answers covering QMSR scope, ISO 13485, FDA inspection changes, exemptions, records, foreign facilities, and quality-system support.

+What is the FDA Quality Management System Regulation (QMSR)?

The Quality Management System Regulation (QMSR) is FDA's current medical-device quality-system regulation in 21 CFR Part 820. It became effective February 2, 2026 and incorporates by reference ISO 13485:2016, along with certain FDA-specific requirements and definitions.

+When did QMSR replace the former Quality System Regulation (QSR)?

QMSR became effective on February 2, 2026. FDA also stopped using the former Quality System Inspection Technique (QSIT) on that date and began using the inspection process described in Compliance Program 7382.850.

+Who is subject to QMSR?

QMSR applies to finished device manufacturers that intend to commercially distribute medical devices. FDA defines a finished device to include devices and certain accessories that are suitable for use or capable of functioning. Device-specific CGMP exemptions may apply, so the exact obligation should be confirmed for the product and activity.

+Are any medical devices exempt from QMSR or CGMP requirements?

Yes. FDA classification regulations identify certain devices that are exempt from some current good manufacturing practice requirements. An exemption does not necessarily remove every quality-system obligation; for example, FDA notes that complaint-file and certain record requirements can still apply.

+Does ISO 13485 certification automatically make a company QMSR compliant?

No. ISO 13485:2016 is the foundational quality-management standard incorporated into QMSR, but FDA-specific requirements under the FD&C Act and implementing regulations still apply. A third-party ISO 13485 certificate is not an FDA certification and does not by itself establish FDA compliance.

+Does FDA require ISO 13485 certification?

FDA requires compliance with QMSR, which incorporates ISO 13485:2016 by reference. FDA does not require manufacturers to obtain a third-party ISO 13485 certificate merely to satisfy QMSR. Certification may be commercially useful or required in other markets, but it is separate from FDA's regulatory determination.

+What is included in a QMSR gap assessment?

A gap assessment typically compares the manufacturer's current quality-management system, procedures, records, and implementation against applicable QMSR and ISO 13485:2016 requirements. The output should identify gaps, risk priorities, responsible owners, and a practical remediation plan.

+Can you help update SOPs and quality documentation for QMSR?

Yes. Support can include quality manuals, procedures, work instructions, document and record controls, supplier controls, complaint processes, CAPA, management review, internal audit processes, training records, and other documentation that applies to the manufacturer's operations.

+How does risk management fit into QMSR?

QMSR incorporates ISO 13485:2016, which uses a risk-based approach throughout the quality management system. Manufacturers should integrate risk-based decision-making into applicable design, production, supplier, process, and postmarket activities rather than treating risk management as a one-time document.

+What happened to FDA's old QSIT inspection approach?

FDA discontinued QSIT on February 2, 2026. Device inspections now use the process described in the updated Inspection of Medical Device Manufacturers Compliance Program 7382.850, which aligns the inspection program with QMSR.

+Can FDA review internal audit, supplier audit, and management review records under QMSR?

Yes. FDA's QMSR FAQ states that the prior record-review exceptions for management review, quality audits, and supplier audit reports were not retained. FDA may review those records during inspection, so they should be maintained and inspection-ready.

+Do foreign medical device manufacturers have the same QMSR obligations?

QMSR applies to covered finished device manufacturers marketing devices in the United States regardless of whether the facility is domestic or foreign. FDA may inspect foreign manufacturing facilities, and the same device-specific exemptions and activity-based analysis should be considered.

+Does QMSR compliance replace medical device registration, listing, UDI, or MDR requirements?

No. QMSR is the quality-system framework. Establishment registration and device listing, labeling and UDI, Medical Device Reporting, corrections and removals, and other FDA requirements remain separate obligations when applicable.

+Can a QMSR issue delay a PMA or create enforcement risk?

Quality-system deficiencies can lead to FDA observations and enforcement action, and significant compliance problems may affect certain regulatory decisions. The consequence depends on the device, submission type, findings, and corrective actions, so the page does not promise that any single QMS issue automatically causes a specific enforcement outcome.

+How often should a medical-device quality system be reviewed?

QMSR does not create one universal annual external-review requirement for every manufacturer. The manufacturer should operate the quality system continuously and perform required management-review, audit, training, CAPA, and other activities at appropriate planned intervals based on its procedures, risks, and applicable requirements.

+How do I get started with QMSR / cGMP support?

Send us your facility details, device types, current quality-system status, existing ISO 13485 certification if any, and the areas you want assessed. We can scope the engagement for gap assessment, documentation support, remediation planning, mock inspection, or ongoing quality-system support.

Get Your QMSR / cGMP Assessment

Submit your facility, device, and quality-system details and we will review the scope and prepare a custom QMSR support proposal.

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