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FDA's QMSR replaced the Quality System Regulation in February

21 CFR Part 820 now incorporates ISO 13485:2016 by reference. For device manufacturers outside the US, the gap just narrowed considerably.

Prem Kumar Dvivedi · 12 September 2026

The FDA's Quality Management System Regulation took effect on 2 February 2026, amending 21 CFR Part 820 to incorporate ISO 13485:2016 by reference and replacing nearly all of the former Quality System Regulation.

Source: US FDA — Quality Management System Regulation (QMSR)

What it means in practice

For a manufacturer already certified to ISO 13485:2016, the change is modest and mostly favourable: one quality system can now satisfy the FDA and the notified body, instead of two sets of documentation saying the same thing in different vocabularies. For a manufacturer that built to the old QSR and never certified to ISO 13485, it is a genuine transition — the standard is structured differently, uses different terms, and asks for risk management across the whole product lifecycle in a way the QSR did not.

The difference that catches people

The QMSR is not simply ISO 13485 with an FDA cover sheet. Certain FDA-specific requirements remain — record-keeping provisions, labelling and packaging controls, and the agency's own definitions where they differ from the standard's. A system built to the standard alone, without reading what Part 820 retains, will be found short in the places the FDA chose not to harmonise.

For exporters

Indian device manufacturers selling into the United States are among the clearest beneficiaries: the certificate many hold for Europe now does most of the work for the US market too. The rest of the work is a gap assessment against the retained FDA provisions, which is a smaller and much better-defined project than the one it replaced.

See how this looks as a working system

Reading about a requirement and seeing the documentation that satisfies it are different things. In a short demo we open the actual manual, procedures and records set for ISO 13485, show you how each clause is answered and where your existing way of working already fits. You will know what implementation involves before you commit to it.

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