SaMD IMDRF category

Significance of the information the software provides × state of the healthcare situation. Based on the IMDRF SaMD risk framework (N12/N41), simplified.

What does the software do with the information?
Healthcare situation / condition

How to use the SaMD IMDRF category helper

Choose what your software does with its output and how serious the healthcare situation is; the helper returns the matching IMDRF category from I to IV. Next, check how a software failure could cause harm with the IEC 62304 software safety class helper, form a US pathway hypothesis with the FDA pathway picker, or return to the free MedTech tools hub.

Need help turning a SaMD category into an evidence plan?

The category is only the starting point: intended-use wording, clinical evaluation depth, and market-specific classification follow from it. Book a Consultation with our clinical / regulatory engineering team to map your SaMD category to an FDA or EU MDR evidence and documentation plan.

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FAQ

What are the IMDRF SaMD risk categories?
The IMDRF SaMD risk framework (N12) sorts software as a medical device into categories I to IV using two factors: the significance of the information the software provides to the healthcare decision (treat or diagnose, drive clinical management, or inform clinical management) and the state of the healthcare situation or condition (critical, serious, or non-serious). Category IV has the highest potential impact on patients and category I the lowest.
What do “treat or diagnose”, “drive” and “inform” clinical management mean?
Treat or diagnose means the output is used to take immediate or near-term action to treat, prevent, mitigate, screen for, or diagnose a condition. Drive clinical management means the output aids treatment or diagnosis, triage, or identification of early signs, guiding the next diagnostic or treatment step. Inform clinical management means the output informs options, for example by aggregating relevant data, without triggering an immediate action.
What counts as software as a medical device (SaMD)?
IMDRF defines SaMD as software intended for one or more medical purposes that performs those purposes without being part of a hardware medical device. Software that drives or is embedded in a hardware device (software in a medical device) is not SaMD, and general wellness or purely administrative software is typically outside the definition.
Is the IMDRF category the same as FDA class or EU MDR class?
No. The IMDRF category is a harmonized risk concept, not a legal classification. FDA classifies devices as Class I, II, or III, and the EU MDR classifies software mainly under Annex VIII Rule 11. The IMDRF factors are useful for reasoning about risk, but the legal class comes from each jurisdiction’s own rules.
How does the IMDRF category affect clinical evaluation?
IMDRF’s SaMD clinical evaluation document (N41) describes three evidence components: valid clinical association, analytical validation, and clinical validation. Higher categories generally call for more rigorous clinical evidence and, for the highest-impact software, independent review of that evidence.

Educational only. Not medical advice, not a regulatory determination, and not a substitute for qualified RA/QA, legal, clinical, or statistical counsel. SaMD IMDRF category does not submit to FDA, Notified Bodies, or IRBs.

Related regulatory tools

Need help turning a SaMD category into an evidence plan?

The category is only the starting point: intended-use wording, clinical evaluation depth, and market-specific classification follow from it. Book a Consultation with our clinical / regulatory engineering team to map your SaMD category to an FDA or EU MDR evidence and documentation plan.

Book a Consultation