Getting Started 1 answer

Are there FDA requirements for non-device clinical decision support software?

Anonymous · Published March 12, 2026 · 1 comment
According to the new FDA guidance on clinical decision support software, our software is classified as a non-device. What are the requirements for bringing such software to the US market? Are there still specific FDA requirements, or is it entirely outside the scope of FDA regulation?

Join the discussion. Leave a comment. Guest comments are welcome — add your email to get reply notifications.

Anonymous 2 months ago
Check if other US laws, such as those related to privacy, might still apply even if FDA requirements do not.
Reply to this comment

Discussion

1 Answer

Accepted answer Dr. Oliver Eidel · Founder & CEO, OpenRegulatory ·
If your assessment shows that your product is truly a “non-device” according to the FDA guidance, there aren’t specific FDA requirements you need to meet to enter the US market. However, keep in mind that other regulations, such as privacy laws, may still apply depending on how your software handles data or interacts with users.

Join the discussion. Leave a comment. Guest comments are welcome — add your email to get reply notifications.

No comments yet. Be the first to share your thoughts.

Want to add your answer to this question?
Write an answer under your name by logging in or signing up, or post anonymously.

Keep reading

All questions
A

Is a US-based test dataset mandatory for FDA clearance of dental AI software?

Anonymous · 1 comment
3 months ago
At our company, we are developing dental AI software and are preparing for FDA clearance in the US. We understand that having data from US sources is beneficial, but is it always mandatory? Our produc
Accepted 4 answers

In my experience, the FDA never explicitly stated what was wrong with our non-US clinical data, but they strongly suggested we include at least one US

A

Why can some US-marketed health software claim disease risk without FDA medical device approval?

Anonymous · 2 comments
3 months ago
I have seen a company marketing its software product in the US, making statements about disease risks (for example, providing cardiovascular or cancer risk scores) directly to consumers. However, they
Accepted 1 answer

The FDA decides if software is a medical device based on its intended use and the specific claims it makes. Here are some reasons why a product might

A

What is my company's role under MDR when incorporating a CE-marked software medical device from another manufacturer into our non-medical app?

Anonymous · 2 comments
6 months ago
I am planning to incorporate a CE-marked software solution (manufactured by another company) into our app, which itself is not a medical device. The software will be made directly available to our use
Accepted 2 answers

We were in a similar situation and the competent authorities defined our role as a distributor. If you are making the CE-marked software medical devic

Still have a question? Ask a question here publicly — for free.

Or talk to one of our consultants — first calls are free. Check out our services and prices.

Looking to automate your regulatory work? Check out our eQMS, Formwork. Built for lean, founder-led companies. There’s a free version too.