Medical device cybersecurity for FDA submissions

    Medical device cybersecurity for FDA submissions.

    Penetration testing, threat modeling, SBOMs, and cybersecurity documentation for your 510(k), De Novo, or PMA submission. We agree the scope and a fixed fee. Your regulatory team reviews and submits the evidence.

    Planning only. A readiness check does not establish regulatory acceptability.

    Evidence aligned with the FDA's February 3, 2026 guidance and eSTAR 7.1. What medical device cybersecurity requires

    • No obligation
    • Expert-led from minute one
    • NDA available on request

    Trusted by leading MedTech teams

    Intuitive Surgical, Blue Goat Cyber client
    bioMérieux, Blue Goat Cyber client
    Inogen, Blue Goat Cyber client
    Natera, Blue Goat Cyber client
    Velico Medical, Blue Goat Cyber client
    Medivis, Blue Goat Cyber client
    Spiro Robotics, Blue Goat Cyber client
    Nova Biomedical, Blue Goat Cyber client
    VitalConnect, Blue Goat Cyber client

    Your device is part of a system

    Cybersecurity follows every connection.

    We look beyond the device enclosure, from firmware and wireless commands to app accounts and cloud APIs.

    1. 01

      Medical device

      Firmware · stored keys · debug ports

      Secure boot & signed updates

    2. 02

      Wireless link

      Bluetooth · Wi-Fi · pairing

      Authentication & replay resistance

    3. 03

      Companion app

      Local data · sessions · commands

      Authorization & secure storage

    4. 04

      Cloud & portal

      APIs · accounts · update delivery

      Access control & tenant isolation

    Illustrative connected system. Scope follows your actual interfaces and architecture; not every device has all four areas.
    Explore medical device pen testing
    The problem

    A cybersecurity deficiency letter puts your review on hold.

    You built a device that helps patients. Your submission needs an SBOM, a threat model, test evidence, and Section 524B documentation. Your engineers are already stretched. Gaps are fixable when you find them early.

    Your review goes on hold

    A 510(k) Additional Information request generally puts substantive review on hold. You get a deadline to respond. Late fixes cost engineering time you planned for launch.

    Gaps are often traceability gaps

    Reviewers need to follow threats to controls to test evidence. A secure device can still draw questions when that trail is missing from the documents.

    Postmarket issues are public

    Vulnerabilities in cleared devices can lead to CISA advisories, FDA safety communications, and recalls. A maintained SBOM and disclosure process help you respond.

    The plan

    Our FDA submission cybersecurity process.

    1. 1

      Book a free 30-minute call

      We can sign an NDA first, then a senior engineer walks through your device and where you are in the submission.

    2. 2

      Get a gap list and a fixed-fee quote

      You see the gaps against the February 2026 FDA guidance, what you already have, and one fixed price to close the rest. No hourly billing.

    3. 3

      Receive the agreed evidence

      We build the agreed documents and testing with you. Your team submits. If the FDA raises a cybersecurity question, we answer it at no extra cost until the cybersecurity portion is closed.

    Track record

    What we've delivered since 2022

    275+
    FDA submissions supported
    Across 510(k), De Novo, and PMA pathways.
    Zero
    Cybersecurity rejections
    Our track record to date. The FDA decides every submission.
    24 hr
    Fixed-fee quote
    A written scope and fixed fee after your discovery call.
    <1 wk
    To start
    Engagements can start less than a week after a signed contract.
    FDA Cybersecurity Deficiency Commitment

    If the FDA raises a cybersecurity question, we answer it at no extra cost until the cybersecurity portion is closed. See why →

    We commit to the work, not to the FDA's decision. Clearance rests with the FDA and depends on factors beyond cybersecurity.

    Services

    Premarket and postmarket cybersecurity services.

    Start with the work you need: a premarket package, standalone testing, a deficiency response, or postmarket support. Each proposal sets out deliverables, required inputs, exclusions, and a fixed fee.

    All services
    Most Requested

    Premarket

    FDA Premarket Cybersecurity Package

    One package for applicable FDA cybersecurity documentation, threat modeling, SBOMs, testing, and submission support.

    What we deliver
    Agreed documentation, threat modeling, SBOMs, testing, and submission support.
    What we need
    Existing cybersecurity documents, architecture, software inventory, and test access.
    Your responsibilities
    Your regulatory team reviews and submits. The FDA decides the outcome.
    View service
    Most Requested

    Premarket

    Medical Device Penetration Testing Services

    Device, firmware, app, and cloud testing for FDA submissions.

    What we deliver
    Test Plan, Test Cases, Test Report, and scoped retest evidence.
    What we need
    Device and test setup, interfaces, architecture, and threat model.
    Your responsibilities
    Standalone testing, not a full submission package. You own fixes and risk decisions.
    View service

    Premarket

    FDA Deficiency Response

    Cybersecurity evidence and technical responses for FDA correspondence.

    What we deliver
    Gap assessment, agreed evidence updates, and a point-by-point technical response.
    What we need
    The FDA letter, current documents, and access for any needed testing.
    Your responsibilities
    You review and submit. Engineering fixes and regulatory review are separate.
    View service

    Postmarket

    FDA Postmarket Cybersecurity

    Vulnerability monitoring, triage, and disclosure support for fielded devices.

    What we deliver
    Agreed monitoring, triage, disclosure support, and reporting records.
    What we need
    Released device configuration, SBOM, and existing vulnerability processes.
    Your responsibilities
    You own patches, release, risk acceptance, and reporting decisions.
    View service

    Premarket

    Medical Device Cybersecurity Consulting

    Premarket-first product cybersecurity consulting, including SSDLC development, with postmarket support when scoped.

    View service

    Premarket

    Medical Device Threat Modeling

    FDA-aligned threat models that identify risks early and speed approvals.

    View service
    New

    Premarket

    AI/ML Medical Device Security

    Defend AI/ML SaMD against adversarial attacks - and meet FDA's PCCP, GMLP, and 2025 AI-enabled device guidance.

    View service

    Premarket

    MedTech Compliance Bundle

    One device security program that covers your FDA submission and the security evidence hospital procurement teams ask for, so buyer reviews don't stall your launch.

    View service
    Where are you?

    Where is your device today?

    Pick the line that sounds like your team. We'll show you the services that solve it.

    Medical Device Cybersecurity

    Medical device cybersecurity, explained.

    Medical device cybersecurity is the set of controls, documentation, and testing used to address risks to device safety and effectiveness from misuse, malicious attacks, and software supply chain vulnerabilities. The manufacturer reviews the evidence and owns risk decisions. It is not generic IT security.

    It focuses on how the device actually operates across hospital networks, patient homes, companion apps, cloud services, and third-party software.

    Why teams call us

    Device makers bring in our senior, US-based engineers to prepare and review cybersecurity evidence. 275+ FDA submissions supported, zero cybersecurity rejections. Our work follows ISO 14971, AAMI TIR57, AAMI SW96, and IEC 81001-5-1.

    Meet the team, visit our About page, read founder Christian Espinosa's profile, see us in the media, or see how our FDA cybersecurity compliance experts work.

    Blue Goat Cyber representatives and peers together in front of the MedTech World sponsor backdrop

    With peers at MedTech World

    Melissa Espinosa at the Blue Goat Cyber booth at The MedTech Conference

    Melissa at The MedTech Conference

    Melissa Espinosa and Dinia Reeves at the Blue Goat Cyber booth at LSI Asia 2026

    Melissa and Dinia at LSI Asia 2026

    From Code Blue Chart

    The threats aren't hypothetical.

    A public-record timeline of medical-device cybersecurity events, sponsored by Blue Goat Cyber.

    View full incident database
    Reality check

    5 cybersecurity misconceptions we see often.

    275+ FDA submissions supported, zero cybersecurity rejections. These are beliefs we encounter in our work. Each can leave gaps in your cybersecurity evidence.

    01

    “My device isn’t a cyber device.”

    All three Section 524B(c) conditions must be met: sponsor-validated, installed, or authorized software; the ability to connect to the internet; and technological characteristics that could be vulnerable to cybersecurity threats. USB charging alone does not establish internet connectivity. Assess actual direct or indirect internet connections, including those through companion systems. Statutory duties and the FDA's guidance recommendations are distinct.

    02

    “My developers know cybersecurity.”

    Secure coding alone does not document the device's cybersecurity evidence. Our threat-modeling scope includes data flow diagrams, trust boundaries, entry points, STRIDE analysis, attack trees, and the Threat Table. The four security architecture views are separate deliverables, not included in standalone threat modeling. A broader premarket proposal can include those views alongside the risk assessment, SBOM, and security testing. Trace threats to controls, applicable tests, and manufacturer-supplied patient-harm context.

    03

    “It’s about protecting data.”

    The FDA's February 2026 final premarket guidance (Section IV) ties device cybersecurity to safety and effectiveness. Data confidentiality alone is too narrow. Your threat model should show how a compromise could harm a patient, make the device unavailable, or corrupt the data it acts on.

    04

    “We’ll add cybersecurity later.”

    The FDA recommends an SPDF with traceability from architecture and threats through security requirements, test evidence, and unresolved-anomaly disposition. Late documentation gaps can require rework; the impact depends on the device and the gaps identified.

    05

    “Traditional IT cybersecurity works.”

    IT pen testing assumes you can take a system offline. Medical device pen testing has to respect availability constraints, you cannot brick an infusion pump mid-test. The Test Report documents tester independence, scope, methods, and results, Scope can include firmware, update paths, and debug interfaces when they are in the threat model. A SOC 2 report or a generic network scan does not show device-level testing.

    + RealitySee what FDA actually expects
    Read the 5 costly misconceptions

    ~4 min read · 275+ FDA submissions supported, zero cybersecurity rejections

    Start with your evidence

    Review your gaps before scoping the work.

    Use the existing tools to organize questions or explore your own assumptions. They do not establish regulatory acceptability or replace a device-specific review.

    Self-assessment

    FDA cyber readiness score

    Review your answers against premarket cybersecurity topics. Use the gap list to plan a discussion, not as a submission decision.

    Scenario calculator

    Cost-of-delay calculator

    Explore a delay scenario using your own revenue and timing assumptions. Results are estimates, not predicted losses or the FDA's review timeline.

    Free PDF

    FDA readiness checklist

    A 20-item self-assessment covering SPDF, SBOM, postmarket monitoring, architecture, and labeling, aligned to the FDA February 2026 premarket cybersecurity guidance.

    How we work

    From discovery to submission. one team, one process.

    01
    30 minutes

    Discovery call

    A senior engineer reviews your device, pathway, and timeline. NDA available.

    02
    Within 24 hrs

    Scope and fixed fee

    A written scope, deliverables, exclusions, and one fixed fee.

    03
    Agreed timeline

    Senior-led work

    Penetration testing, threat modeling, SBOMs, and documentation. Every FDA-facing document is senior-reviewed.

    04
    Before you submit

    Evidence handoff

    The agreed evidence for your eSTAR, with retests included. Your team submits.

    05
    After clearance

    Postmarket support

    Optional vulnerability monitoring, SBOM maintenance, and disclosure support.

    Case studies

    Real wins, anonymized.

    Device names and clients are confidential. These engagements were scoped and documented for FDA review.

    All case studies
    Class II SaMD (De Novo)

    Series-B imaging AI manufacturer (US, ~60 FTEs)

    Imaging & AI/SaMD

    Challenge

    An FDA reviewer issued a cybersecurity AI Request on a De Novo submission for an AI triage SaMD, citing an incomplete threat model, a non-conformant SBOM, and missing evidence that the model-loading pipeline had been security-tested. The team had 30 days to respond, no in-house cybersecurity lead, and an investor-board commitment to a Q3 commercial launch.

      Class II 510(k)

      Cardiac remote-monitoring manufacturer (US/EU dual market)

      Cardiovascular

      Challenge

      A connected cardiac event monitor with cellular backhaul needed a complete premarket cybersecurity package for a 510(k), with the device launching to a national hospital network at scale. The MCU firmware had been carried over from a legacy un-cleared product line, secure boot was implemented but never audited, and the cellular AT-command surface had never been fuzzed.

        Class III PMA

        Implantable neurostimulator manufacturer (Class III, life-sustaining)

        Neuromodulation / Active Implantables

        Challenge

        A pre-PMA implantable neurostimulator with a wireless programmer, patient remote, and cloud telemetry needed a full Section 524B cybersecurity package that would survive an Advisory Panel and a multi-cycle PMA review - with patient-safety risk tolerances far tighter than a typical 510(k). The device is life-sustaining, the radio link is proprietary, and a successful attack on the firmware update path would be unrecoverable in the field.

          Want references in your device class? Ask on your discovery call , we can connect you with clients under NDA.

          Meet us in person

          Title sponsor of MedTech World.

          Blue Goat Cyber is title sponsor of every MedTech World summit. Our team keynotes, judges, and mentors across the US, EMEA, and APAC, because the firms shaping the next generation of medical devices are the same firms we work with every day.

          All events
          Title SponsorEurope

          MedTech World Europe

          Nov 11-13, 2026

          Valletta, Malta

          Event details →
          AttendingNorth America

          QNova LifeSciences 13th Annual Partnering Forum (JPM Week)

          Jan 11-14, 2027

          San Francisco, CA, USA

          Event details →
          Title SponsorMiddle East

          MedTech World Middle East

          Mar 23-25, 2027

          Dubai, UAE

          Event details →
          Title SponsorNorth America

          MedTech World North America

          May 5-7, 2027

          West Palm Beach, FL, USA

          Event details →
          Industry recognition

          Award-winning. Globally recognized.

          Our work has been honored by the leading voices in medical device cybersecurity.

          2026

          Medical Device Cybersecurity Solution of the Year

          Medical Tech Outlook

          Cover story profiling Blue Goat Cyber as a top industry leader.

          2026

          Medical Device Cybersecurity Partner of the Year

          MedTech World North America

          Inaugural North America Awards, in collaboration with CS Lifesciences, recognition of our patient-safety-first approach to FDA cybersecurity submissions.

          2025

          MedTech Service Provider Excellence Award of the Year

          MedTech World Malta · sponsored by the Malta Medicines Authority

          Honored on the global MedTech stage for FDA-facing cybersecurity work.

          Offensive security credentials

          The certifications that actually break into devices.

          Our team holds the offensive security certifications real attackers respect, backed by hands-on U.S. government red team and military cyber operations experience.

          CISSP

          Certified Information Systems Security Professional

          OSCP

          Offensive Security Certified Professional

          PNPT

          Practical Network Penetration Tester

          CBBH

          Certified Bug Bounty Hunter

          Security+

          CompTIA Security+

          PMP

          Project Management Professional

          Regulatory frameworks

          The standards behind your cybersecurity documentation.

          We speak the language so your team doesn't have to learn it from scratch. Each framework below maps to a specific deliverable in your submission package.

          Not sure which apply to you?

          The Standards Decoder maps each framework to your submission pathway, 510(k), De Novo, or PMA, and the artifacts the FDA expects against each.

          Browse the standards glossary

          We also align with

          FDA 2026 Premarket Guidance · ANSI/AAMI SW96 · ISO 13485 · ISO 14971 · FDA Section 524B · AAMI TIR57 · AAMI TIR97 · IEC 81001-5-1 · IEC 62443-4-1 · IEC 62304 · NIST 800-115 · ISO 27001 · UL 2900

          Free resource · PDF

          The MedTech Cybersecurity Standards Decoder

          FDA Section 524B, AAMI SW96, ISO 14971, IEC 81001-5-1, and more, what each requires, how they connect, and what the FDA expects to see. No email, no signup.

          FAQ

          Medical device cybersecurity, answered.

          The questions MedTech teams ask us most about FDA cybersecurity expectations, SBOMs, pen testing, and what regulators actually want to see.

          What does the FDA actually require for medical device cybersecurity?
          Section 524B applies to cyber device submissions through 510(k), PMA, PDP, De Novo, and HDE pathways, not IDEs. It requires a postmarket monitoring and coordinated vulnerability disclosure plan, processes for cybersecurity and patches, and an SBOM submitted to the FDA. The February 3, 2026 final guidance recommends an SPDF, threat modeling, security architecture views, cybersecurity risk assessment, security testing, and labeling. VEX is optional; independent testers may be internal or external, and no specific SBOM format or version is mandated.
          Which devices count as 'cyber devices' under Section 524B?
          Section 524B(c) defines a cyber device by three conditions, all of which must be met: it includes software validated, installed, or authorized by the sponsor; it has the ability to connect to the internet; and it contains technological characteristics that could be vulnerable to cybersecurity threats. A USB charging port alone does not establish internet connectivity. BLE pairing or a companion app requires assessment of the device's actual connectivity, including indirect internet connections. For applicable cyber device submissions, Section 524B establishes statutory obligations. The FDA's guidance separately recommends cybersecurity documentation and testing to support review.
          Do I need a SBOM, and what format does the FDA expect?
          Section 524B(b)(3) requires an SBOM for applicable cyber device submissions. The FDA recommends a machine-readable, industry-accepted format, with component support levels and end-of-support information. Neither SPDX nor CycloneDX is mandated by the FDA. Blue Goat uses SPDX as the default delivery format. CycloneDX can be used when agreed during scoping. Optional VEX statements document vulnerability status and supporting evidence; they do not replace the SBOM or postmarket vulnerability management.
          How long does premarket cybersecurity work usually take?
          It depends on device complexity, available documents, test access, and how many fixes your engineers need to make. We give you a timeline after scoping. Engagements can start less than a week after a signed contract. The fee is fixed. Our work does not set the FDA's review timeline.
          What happens if the FDA issues a cybersecurity deficiency letter?
          The letter identifies the questions and applicable response deadline. A 510(k) Additional Information request generally places substantive review on hold and allows 180 calendar days to respond before the submission is considered withdrawn. Other letters and pathways can have different deadlines. We assess the cited gaps, map them to applicable statutory provisions and guidance recommendations, and prepare scoped documentation, testing, and a point-by-point response. The manufacturer submits the response. The FDA controls review timing and submission disposition; Blue Goat cannot preserve a queue position or promise an outcome. 275+ FDA submissions supported, zero cybersecurity rejections.
          Is penetration testing required, and is automated scanning enough?
          The FDA recommends security requirements testing, threat mitigation testing, vulnerability testing, and penetration testing. Testers should be independent of device development and may be internal or external. We provide penetration testing scoped to the device interfaces and threat model, with documented methods, findings, and retest evidence; third-party testing and a Letter of Attestation are not statutory requirements.
          What about postmarket cybersecurity obligations?
          Section 524B(b)(1) requires a plan to monitor, identify, and address postmarket vulnerabilities, including coordinated vulnerability disclosure. Section 524B(b)(2) requires processes for updates and patches. The FDA's guidance recommends how to run and document that work. Blue Goat can support monitoring, triage, disclosure intake, and reporting. The manufacturer owns fixes, risk acceptance, release, and any reporting decisions.
          We haven't filed our premarket submission yet. When should we engage?
          As early as design inputs. The FDA recommends an SPDF that integrates security throughout development, with traceability from threats and security requirements to controls and testing. Existing documentation can be improved later, but late gaps can add rework. We support teams at concept, near filing, and during deficiency responses.

          Get in touch

          Tell us about your device.

          A senior MedTech cybersecurity engineer will reply within one business day with a clear next step, no sales rep, no scripted call.

          • Senior engineer on the first reply
          • Aligned to FDA's 2026 premarket guidance
          • FDA cybersecurity deficiency commitment

          Talk to a medical device cyber expert

          Reply within one business day. Prefer to skip the form? Book a strategy session.

          Start here

          Ready to see your cybersecurity gaps before the FDA does?

          A free 30-minute Discovery Session with a senior MedTech expert. Walk away with a scoping plan and clear next steps.