08 Service

Post-market surveillance and lifecycle compliance

The certificate is issued and the device is on the market, and the obligations have just begun. A PMS system that only collects complaints misses the signals, misses the deadlines and leaves the PSUR to be written from memory. Authentcare builds the system so that each report is produced from data the system already holds, on the cadence each market sets.

Capability
Direct — delivered by the consultant
First deliverable
PMS system review
Typical turnaround
10 working days

The situation

The device is on the market and the obligations are now continuous. A PSUR is due and the data for it lives in five places. A complaint arrived that someone thinks might be reportable and nobody is sure in which market, by when. A notified body has asked how the PMS plan feeds the clinical evaluation. A distributor in India has mentioned the Materiovigilance Programme and nobody in head office has heard of it.

What goes wrong when this is handled late

Post-market systems built after the certificate fail in predictable ways. Complaints are categorised by the complaint handler's words rather than by the hazard list, so trends are invisible. The PSUR is written from memory, without exposure data, and reads as an assurance rather than an analysis. Vigilance decisions are made case by case without a recorded method, so the one that goes wrong cannot be defended. PMCF is a plan on paper with no data behind it when the clinical evaluation comes up for renewal. And a signal that should have changed the risk file never reaches it, because the two systems were never connected.

What Authentcare does

Assess. Review the PMS system against MDR Chapter VII and Annex III, IVDR Chapter VII, the FDA's Part 803 and 806 requirements, the QMSR and ISO 13485 clause 8, and India's Materiovigilance Programme as your markets require. Check that the PMS plan is proportionate to class and risk, that complaint categories map to hazards, that the vigilance decision method is written and that the PSUR calendar is right.

Develop. Build the PMS system and plan; the complaint-handling procedure and categorisation; the vigilance procedure with its market annexes; the trend-reporting method and thresholds; the PMCF or PMPF plan integrated with the clinical or performance evaluation; and the CAPA linkage so that post-market findings re-enter the risk file and the design. Prepare the PMS report or PSUR from the system's data, on the cadence the class requires.

Coordinate. Support each vigilance decision and report, in the manufacturer's name, within the timelines. Prepare the PSUR for the notified body's review. Keep the EUDAMED position under review: the Actor, UDI/Device, Notified Bodies and Certificates and Market Surveillance modules have been mandatory since 28 May 2026, while vigilance continues through national routes until the Vigilance module is mandated.

Which report your device needs

Device Report Cadence Basis
MDR Class I PMS report Updated when necessary; available on request MDR Article 85
MDR Class IIa PSUR At least every two years MDR Article 86
MDR Class IIb and III PSUR At least annually; IIb implantable and III submitted to the notified body MDR Article 86
IVDR Class A and B PMS report Updated when necessary; available on request IVDR Article 80
IVDR Class C and D PSUR At least annually IVDR Article 81
Any device in the US Medical device reports and corrections and removals as events require Event-driven, within statutory timelines 21 CFR 803 and 806
Any device in India Adverse event reports under the Materiovigilance Programme Event-driven Medical Devices Rules 2017

What you receive

  • PMS system and PMS plan to MDR Article 84 and Annex III, or IVDR Article 79, proportionate to class and risk
  • PMS report (MDR Article 85, Class I) or PSUR (MDR Article 86, Class IIa, IIb and III; IVDR Article 81), prepared on the cadence the class requires, following MDCG 2022-21
  • PMCF plan and evaluation report, or PMPF plan and report for IVDs, integrated with the clinical or performance evaluation
  • Complaint-handling procedure and complaint categorisation built from the hazard list
  • Vigilance procedures — serious incident reporting, field safety corrective actions and field safety notices — with the timelines per market and the MDCG 2023-3 terminology
  • Trend reporting method and thresholds under MDR Article 88
  • FDA medical device reporting (21 CFR 803) and corrections and removals (21 CFR 806) procedures
  • Materiovigilance Programme of India reporting procedure under the Medical Devices Rules 2017
  • CAPA linkage so that post-market signals re-enter the risk file and the design

Frameworks and editions

Applicability is device-specific. Which of these apply, and in what combination, depends on device type, intended purpose, classification and target market; the applicability assessment at the start of every engagement settles it in writing.

Frameworks and current editions cited on this page
ReferenceEdition or version citedWhere it applies
EU MDR 2017/745 Chapter VII and Annex III; IVDR 2017/746 Chapter VIIAs amendedPMS, PSUR, vigilance, trend reporting and market surveillance
MDCG 2022-21Current revisionPSUR content and format
MDCG 2023-3Current revisionVigilance terms and concepts
21 CFR Part 803 and Part 806Current CFRFDA medical device reporting; reports of corrections and removals
FDA QMSR, 21 CFR Part 820; ISO 13485:2016 clause 8In force since 2 February 2026; third edition with Amendment 1:2024Complaint files, feedback, CAPA
India Medical Devices Rules 2017; Materiovigilance Programme of IndiaAs amended; current MvPI guidanceAdverse event reporting and post-approval obligations in India
Commission Decision (EU) 2025/2371EUDAMED Actor, UDI/Device, NB and Certificates, Market Surveillance modules mandatory since 28 May 2026; Vigilance module not yet mandatoryVigilance continues through national routes until the module is mandated

What this engagement excludes

  • Making vigilance reports in the manufacturer's name; the manufacturer or its authorised representative submits, Authentcare prepares
  • Clinical or performance study execution for PMCF or PMPF
  • Complaint intake operations; the system is designed, the manufacturer runs it
  • Regulator fees

Boundary

Reporting obligations and timelines belong to the manufacturer; Authentcare builds the system and supports each report.

Questions manufacturers ask

Ready to scope the work?

Bring the device description, the markets you want and whatever documentation exists. Thirty minutes is enough to know what comes first.