The short answer

Since February 2, 2026, FDA’s quality system rules for medical devices are the Quality Management System Regulation (QMSR) in 21 CFR part 820. The QMSR incorporates ISO 13485:2016 by reference, plus clause 3 of ISO 9000:2015 for definitions. It replaced the old Quality System Regulation (QSR). On the same day FDA stopped using its old QSIT inspection method and started inspecting under a new compliance program, 7382.850.

For foreign device makers this is mostly good news: a well-run ISO 13485 system is now the foundation of U.S. compliance. But an ISO 13485 certificate is not a substitute for meeting FDA’s extra requirements or for an FDA inspection.

ItemDetail
Final ruleMedical Devices; Quality System Regulation Amendments — FR Doc. 2024-01709 (February 2, 2024)
Effective dateFebruary 2, 2026
Standard incorporatedISO 13485:2016, plus clause 3 of ISO 9000:2015
InspectionsQSIT retired; Compliance Program 7382.850, “Inspection of Medical Device Manufacturers”
Where FDA and ISO differIf an ISO 13485 clause conflicts with the FD&C Act or FDA regulations, FDA’s requirements control

What changed in practice

How FDA inspects now

Compliance Program 7382.850 groups the quality system into six areas, and investigators choose elements based on patient risk:

  1. 1Change controlHow design, process and supplier changes are assessed and approved.
  2. 2Design and developmentDesign inputs, verification, validation, risk management and software.
  3. 3Management oversightQuality policy, management review and internal audits.
  4. 4Measurement, analysis and improvementComplaints, nonconformities, CAPA and data trends.
  5. 5Outsourcing and purchasingSupplier control, including contract manufacturers and component suppliers.
  6. 6Production and service provisionProcess validation, sterilization, labeling and packaging controls.

Investigators also check the other FDA requirements: MDR, corrections and removals, tracking and UDI.

Example: a glove maker in Malaysia

A factory making medical examination gloves already holds ISO 13485 certification. To be ready for an FDA inspection under the QMSR, it checks that its risk files cover each glove type, that management review and internal audit records are complete (FDA can now ask to see them), that its UDI and labeling controls meet FDA rules, and that its complaint handling feeds into MDR decisions. The certificate helps — but FDA judges the records.

Checklist for foreign device makers

Device registration and listing

FDA medical device establishment registration with U.S. Agent $550. Device listing $50. GUDID account assistance $250. Device label review $550.

See device services →

Frequently asked questions

When did the QMSR take effect?

February 2, 2026. The final rule was published on February 2, 2024, with a two-year transition.

Does ISO 13485 certification mean I comply with the QMSR?

It is a strong base, but not enough on its own. The QMSR adds FDA-specific requirements, and FDA inspects your records directly; a certificate does not replace an FDA inspection.

What replaced QSIT?

Compliance Program 7382.850, “Inspection of Medical Device Manufacturers”, which FDA began using on February 2, 2026.

Can FDA now review internal audit and management review reports?

Yes. Management reviews and internal audits are part of the new inspection areas, and FDA’s QMSR FAQ says supplier audit reports are also subject to review.

Sources

Dates and requirements checked on November 11, 2026. This article is general information, not legal advice.