What regulated QA actually requires

Practice · Regulated Quality Assurance

Regulated QA under ISO 13485 and IEC 62304 is a specific, auditable set of obligations, not more testing: a documented quality system, a safety classification behind every requirement, verification and validation evidenced separately, and a requirements traceability matrix an outside reviewer can follow across all 5 clauses of IEC 62304 life-cycle process.

What does regulated QA require beyond testing?

Regulated QA under ISO 13485 and IEC 62304 is a specific, auditable set of obligations, not more testing. It requires a documented quality system, a safety classification behind every requirement, separately evidenced verification and validation, and a traceability matrix an outside reviewer can follow.

Miss any one of these and the software may work perfectly and still fail an audit.

Four obligations a "we test thoroughly" claim doesn't cover

Most engineering teams already test their software. Regulated QA adds four specific, checkable obligations on top of that — each one independently auditable, each one a place audits actually find gaps.

1. A documented quality system, not tribal knowledge

ISO 13485 and IEC 62304 both require a quality management system that exists independent of any one engineer's memory: who approves a requirement, who verifies a unit, who releases a build, and where the record of each lives. If the process only exists in a senior engineer's head, it does not exist for audit purposes.

2. Risk-based classification before rigor is assigned

Per IEC 62304 §4.3, every MedTech software item gets a Safety Classification (A/B/C) driven by the severity of harm it could contribute to if it failed — determined through an ISO 14971 risk analysis and its hazard analysis, not by how complex the code looks. Classification comes first; it's what tells you how much rigor Clause 5 actually demands for that item.

3. Verification AND validation, evidenced separately

"We tested it" collapses two distinct, separately-required activities into one claim. See Verification vs. Validation in High-Consequence Systems for the full distinction — the short version: verification proves you built the thing right; validation proves you built the right thing. Regulated QA requires evidence of both, not one standing in for the other.

4. A traceability chain a stranger can follow

The single most common MedTech regulated-QA audit finding under IEC 62304 isn't a missing document — it's a broken link in the requirements traceability matrix between a requirement, the design element that implements it, the test that verifies it, and the risk control it satisfies. See Requirements-to-Test Traceability Matrix Guide for how to keep that chain from drifting.

Minimum-viable regulated QA checklist

A working self-check — five yes/no items, each independently auditable.

[ ] A documented quality system names who approves, verifies, and releases
[ ] Every software item has a Safety Classification (A/B/C) with a recorded
    rationale traced to an ISO 14971 risk analysis
[ ] Verification and validation are each independently evidenced
    (not one used to imply the other)
[ ] Every requirement traces to a design element, a test, and a risk
    control -- and that chain is regenerable, not hand-maintained
[ ] A release record exists that references all of the above by ID,
    not by narrative summary

Engineering reference only. Not formal regulatory counsel. Consult your own quality system and legal counsel for a specific regulatory determination.

Provenance & review state

Last reviewed
Sources
  • IEC 62304:2006+AMD1:2015 — International Electrotechnical Commission
  • ISO 14971:2019 — International Organization for Standardization
  • ISO 13485:2016 — International Organization for Standardization
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