IVD Post-Market Surveillance: Best Practices Under IVDR 

In the rapidly evolving landscape of in vitro diagnostic (IVD) regulations, the implementation of the In Vitro Diagnostic Regulation (IVDR) marks a significant shift. This new regulation demands more rigorous post-market surveillance (PMS) processes, ensuring that IVD devices continue to perform safely and effectively after they have been introduced to the market. For executives navigating these changes, understanding and implementing best practices in PMS under IVDR is crucial. Here, we outline key strategies to enhance your company’s compliance and ensure ongoing market success. 

Understanding IVDR Requirements 

The IVDR, which fully applies from May 2022, emphasizes a robust approach to PMS. This regulatory framework mandates that manufacturers collect and analyze real-world data post-launch to confirm safety and performance over the entire lifecycle of the product. The core elements include the Post-Market Surveillance Plan, Periodic Safety Update Report (PSUR), and Post-Market Clinical Follow-up (PMCF) studies.

Develop a Comprehensive PMS Plan

A strategic PMS plan is the foundation of effective post-market surveillance under IVDR. This plan should outline specific methods and practices for gathering and evaluating data on your IVD devices. It should cover: 

Data collection: Utilize multiple sources such as clinical follow-up, feedback from users, and literature reviews. According to a study published in The Journal of Medical Regulation, integrating comprehensive data collection strategies leads to a 20% improvement in regulatory compliance and device safety. 

Risk management: Continuously update the risk management file with new information that could impact the risk assessment of the device. 

Performance evaluation: Regularly assess and document the performance and clinical utility of the device based on real-world data.

Periodic Safety Update Reports (PSUR)

For Class B, C, and D IVD devices, the IVDR requires periodic safety update reports every two to five years, depending on the device class. These reports must provide a comprehensive analysis of the benefit-risk balance, summary of the PMS data, conclusions from the collected data, and a rationale for any preventive or corrective actions taken. Establishing a routine schedule for reviewing and updating these reports is vital to maintaining compliance and enhancing device safety.

Engage in Active Post-Market Clinical Follow-Up (PMCF)

PMCF is an ongoing process to continually assess an IVD device’s clinical performance and to ensure it meets its intended purpose without compromising patient safety. This may involve gathering additional data, conducting further studies, or implementing corrective actions when necessary. The data collected through PMCF should feed back into the PMS plan, creating a dynamic process of continual improvement.

Utilize Technology and Data Analytics

Advancements in technology and data analytics offer unprecedented opportunities to streamline PMS processes. Implementing software solutions that can integrate and analyze large datasets efficiently is increasingly crucial. These tools can help in identifying trends, predicting potential device failures, and facilitating rapid response strategies.

Training and Internal Communication

Ensuring that your team understands the IVDR requirements and the importance of effective PMS is essential. Regular training sessions and clear internal communication strategies can help in maintaining a culture of compliance and vigilance throughout your organization. 


The IVDR brings with it a more stringent regulatory environment with a strong focus on post-market surveillance. By establishing robust PMS practices, not only can IVD manufacturers ensure compliance with the new regulations, but they can also significantly contribute to the enhanced safety and effectiveness of medical devices. In the long run, these practices will support sustainable business operations by building trust with consumers and regulatory bodies alike. As we move forward in this new regulatory era, embracing these best practices will be key to thriving in the global market. 

For more insights into optimizing your regulatory processes, visit Criterion Edge. 

About the Blog

In this blog, we share our insights and experiences to help companies build quality, scalability, and flexibility into their regulatory writing.  We hope you find it insightful. For questions, please contact info@criterionedge.com.

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