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FAQs
Inspection Readiness & Quality Systems

Q8: What changed under QMSR and does our ISO 13485 certification still satisfy FDA?

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The FDA's Quality Management System Regulation (QMSR) became effective February 2, 2026, replacing the legacy Quality System Regulation (QSR) and incorporating ISO 13485:2016 by reference into 21 CFR Part 820.

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The transition harmonizes U.S. device QMS requirements with the international standard. However, it does not mean that ISO 13485 certification alone satisfies QMSR.

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FDA has clearly stated that ISO 13485 certification does not exempt a manufacturer from FDA inspection. Companies can be fully certified and still receive FDA Form 483 observations if they do not recognize the FDA’s additional requirements.

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Six months into QMSR enforcement, the most consistent finding is that companies that treated the transition as a documentation renaming exercise are encountering inspection gaps. A significant difference between the legacy QSR requirements and the new QMSR is considerably more emphasis on product lifecycle risk management based on ISO 13485 and ISO 14971:2019:  Medical Devices — Application of Risk Management.  Landrich Group supports QMSR gap assessments and mock audits calibrated to the new inspection framework and providing confidence for ensuring FDA inspection readiness.

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