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Medical Device Software in 2026: FDA Cybersecurity (Section 524B) and the New QMSR

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October 26, 2026

6 min read

Cyber devices must include an SBOM, a vulnerability management plan and evidence of secure design in every premarket submission, and FDA's final guidance from June 2025 explains what reviewers expect. On February 2, 2026 the QMSR replaced the old Quality System Regulation with ISO 13485 by reference. What that means for software and cloud components running on AWS.

Medical Devices
FDA
SBOM
Healthcare
Cybersecurity

Software as a medical device, and devices with a cloud backend, now face two sets of requirements that touch infrastructure directly: section 524B of the FD&C Act for cyber devices, and the Quality Management System Regulation (QMSR).

Section 524B, in practice

A cyber device is one that includes software, can connect to the internet, and could be vulnerable to cyber threats. Anyone submitting a 510(k), PMA, De Novo, PDP or HDE for one must provide:

  • A plan to monitor, identify and address postmarket vulnerabilities, including coordinated disclosure.

  • Processes that provide reasonable assurance the device and related systems are cybersecure, with updates and patches on a regular cycle and out of cycle for critical issues.

  • A software bill of materials covering commercial, open-source and off-the-shelf components.

FDA's final guidance, "Cybersecurity in Medical Devices: Quality System Considerations and Content of Premarket Submissions", issued June 27, 2025, sets out what reviewers expect: threat modelling, security architecture views, testing evidence, and the SBOM with support status for each component.

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The QMSR

Since February 2, 2026, 21 CFR Part 820 incorporates ISO 13485:2016 by reference, and FDA inspects against it. Companies already certified to ISO 13485 have less to change; those built around the old Quality System Regulation have a gap analysis to do. Software development, configuration management and supplier controls all sit inside the quality system, and that includes cloud infrastructure.

Cloud components on AWS

Expectation

How we meet it on AWS

SBOM for the whole system

Generated in CI for every image and function; Amazon Inspector can export SBOMs for scanned resources

Vulnerability monitoring

Inspector scanning of images, functions and instances, triaged against the device's threat model

Controlled, documented changes

Infrastructure as code, reviewed and traceable to requirements; no console changes in production

Supplier controls

AWS treated as a supplier in the QMS, using its compliance reports from AWS Artifact

Patching on a cycle

Managed services where possible, so the patching burden is AWS's; rebuilt images on a schedule otherwise

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As of October 26, 2026. Provided as is, for general information, and accurate to the best of our knowledge on the date shown. Not legal, compliance, tax, financial or other professional advice. Prices, limits and vendor services change; check current vendor documentation before relying on anything here. Terms of use.