Cybersecurity for medical devices

Cybersecurity that fits into your regulatory framework

MDR, IEC 62304, ISO 14971, ISO 13485: you already meet more safety and quality requirements than most industries. We build on that instead of duplicating it: we clarify where the CRA and the AI Act additionally apply and what is exempt, and we integrate cybersecurity with your existing QM and risk management.

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Audits
Notified bodies actively ask for security evidence
Recalls
Vulnerabilities have already led to market actions
Hospital IT
Your products run in networks under attack every day
Procurement
Tenders increasingly require security evidence

Sound familiar?

Questions we keep hearing from regulatory, quality and R&D teams.

"Does the CRA even apply to our product?"

Certain sector-regulated medical devices are exempt from the CRA, but not every product in your portfolio falls under that exemption. Companion software without a medical purpose, platforms or accessories may be in scope. The scoping decision determines your effort.

"We have ISO 13485 and 14971 – how much of that counts?"

More than you might think. Risk management, development processes, CAPA and post-market surveillance provide building blocks that can be credited towards cybersecurity. What is usually missing is the security-specific extension, not a rebuild.

"MDR, CRA, AI Act – who ties it all together?"

Three legal acts, overlapping requirements, different deadlines. Without the full picture you risk duplicate documentation and contradictory processes. You need a map, not a third parallel structure.

"What if the notified body starts asking questions?"

Cybersecurity has long been an audit topic, in MDR audits as well as in the technical documentation review. Findings cost time and, in the worst case, market access. Properly integrated security evidence takes the fear out of the topic.

MDR · CRA · AI Act

Where the CRA and AI Act apply to medical devices

Three legal frameworks, one product. What matters is clean scoping: what applies, what is exempt, and from when.

MDR & standards: your foundation

The MDR's safety requirements already apply today, and your existing standards cover a lot of ground.

  • MDR Annex I: general requirements incl. IT security
  • IEC 62304: software life cycle
  • ISO 14971: risk management, extendable to security risks
  • MDCG 2019-16 and IEC 81001-5-1 as security guidance

CRA: not for all, but for some

Medical devices under the MDR/IVDR are exempt from the CRA. The exemption ends at the product boundary, though.

  • In force since late 2024
  • Reporting obligations in effect since September 2026, full requirements from December 2027
  • Exemption for sector-regulated medical devices
  • Companion software, platforms and products without a medical purpose may be in scope

AI Act: on top

AI/ML in medical devices qualifies as product-regulated high-risk AI under Annex I of the AI Act.

  • High-risk classification for AI in medical devices (Annex I)
  • Obligations apply from August 2028, after the postponement from May 2026
  • Requirements on risk management, data governance, robustness and cybersecurity
  • Can be aligned with the MDR conformity assessment

Scoping is rarely trivial in practice and determines effort and timeline. That is exactly what we clarify together in the intro call.

How we help

We build on what your QM system already delivers and add precisely what is missing for cybersecurity.

Clarify scope before you invest

We classify your product portfolio: what falls under the CRA exemption, what does not, and where the AI Act applies. So you spend effort where it is actually required by regulation.

Credit what you have instead of rebuilding

Risk management per ISO 14971, development processes per IEC 62304, CAPA and post-market surveillance: we identify which artefacts you can reuse for cybersecurity and close only the real gaps.

Extend processes, don't duplicate them

We set up vulnerability management, PSIRT and reporting processes as extensions of your existing QM processes, with clear responsibilities and audit-proof documentation.

Align security documentation with your MDR documentation

We integrate threat model, security risk analysis, SBOM and test evidence into your technical documentation so that notified bodies and auditors see one consistent picture.

Our packages for MedTech

Fixed prices, clearly defined scope, defined deliverables. Each package can be booked individually and builds on your existing QM artefacts.

Recommended entry point

Product gap analysis

€2,000

Where does your product stand against the cybersecurity requirements? Crediting what ISO 13485 and ISO 14971 already cover.

  • Prioritised gap list
  • Credit for existing QM and risk artefacts
  • Action plan with effort estimates

AI-based security scan

from €4,900

The security overview of your product portfolio: within three to five days we test your entire external attack surface for the most critical and most common vulnerabilities, automated and manually validated.

  • Breadth over depth: the whole portfolio instead of a single system
  • Critical findings manually verified, with proof of concept
  • Prioritised report with quick-win list
  • Clear recommendation on where deeper testing pays off
Workshop

Product cybersecurity for MedTech

from €2,200

Bring your team up to speed: secure development, threat modeling and regulatory context, in the MedTech variant with greater regulatory depth.

  • Remote or on site
  • Tailored to your products and processes
  • MDR, CRA and AI Act context included

All prices excl. VAT. No package fits exactly? In the intro call we work out which scope makes sense for your product.

Why ActSecure for MedTech

Regulatory depth and development practice from a single source.

Regulatory depth

We know the MDR, IEC 62304, ISO 14971 and ISO 13485 from projects, not from the textbook. We speak the language of your notified body and your QM team.

Development practice

Over ten years of software development in digital health: threat modeling, secure architectures and security testing that works in day-to-day development rather than just on paper.

From a single source

Regulatory assessment and technical implementation come from one team, without friction and without the overhead of a large consultancy.

FAQ

Frequently asked questions

Aren't medical devices exempt from the CRA anyway?

Only partially. The exemption applies to products that are already sector-regulated, in particular under the MDR and IVDR. It ends at the product boundary, though: companion software without a medical purpose, platforms, accessories or products outside the MDR may fall under the CRA. We clarify per product whether and where this affects you in the intro call.

How much of ISO 13485 and ISO 14971 can we credit?

Quite a bit. Your ISO 14971 risk management can be extended to cover security risks instead of building a second risk management system. Development processes per IEC 62304, CAPA, post-market surveillance and your documentation structure provide further building blocks. In the gap analysis we state precisely what can be credited and what needs a security-specific addition.

How does cybersecurity interact with the MDR?

Annex I of the MDR already requires state-of-the-art IT security; MDCG 2019-16 and IEC 81001-5-1 specify what that means in practice. Cybersecurity is therefore not a new rulebook next to the MDR but part of your conformity. We align the security evidence with your technical documentation so the notified body sees one consistent picture.

Which deadlines do we need to keep in mind?

For products in scope of the CRA, reporting obligations have applied since 11 September 2026, and the full requirements follow from 11 December 2027. For high-risk AI in product-regulated areas (Annex I of the AI Act, including medical devices), the obligations apply from August 2028 after the postponement. The MDR's IT security requirements, however, already apply today.

We have AI in our product. What does that mean for us?

AI/ML features in medical devices are generally classified as high-risk AI under Annex I of the AI Act. This brings requirements on risk management, data governance, robustness and cybersecurity, which can be aligned with your MDR conformity assessment. Our AI-based security scan gives you the security overview of your attack surface and shows where deeper testing is needed.

Doesn't this end up meaning duplicate documentation?

Not if it is set up properly. That is exactly what most of our clients are rightly wary of. Our approach is to integrate security requirements into existing processes and documents: one risk management system, one set of technical documentation, extended rather than duplicated.

Let's talk about your product

In a free intro call we clarify whether you are affected, what the sensible next steps are, and which package fits your situation. No strings attached.

info@actsecure.eu