Medical Device Cybersecurity

    FDA Premarket Cybersecurity Package

    Your submission deadline is close. We cover all applicable FDA premarket cybersecurity requirements for your device, including documentation, testing, and submission support, with one team and a fixed-fee scope.

    The short answer

    What's in an FDA premarket cybersecurity package?

    The FDA Premarket Cybersecurity Package brings threat modeling, cybersecurity risk assessment, security architecture, SBOM work, security testing, labeling, and vulnerability management planning into one traceable evidence set. We scope the work to your device and pathway, distinguish Section 524B obligations from guidance recommendations, and support the cybersecurity portion of FDA review. IDE work is scoped to investigational use rather than treated as a Section 524B marketing submission.

    275+ Devices Supported. Cybersecurity Work Owned In-House.

    • Fixed-fee scope
    • Uncontrolled-risk retests included
    • Cybersecurity deficiency support
    • eSTAR v7.1 aligned
    • Free 30-minute call
    • Fixed-fee quote after scoping
    • NDA available on request

    Trusted by leading MedTech companies

    Intuitive Surgical logo, Blue Goat Cyber client
    bioMérieux logo, Blue Goat Cyber client
    Inogen logo, Blue Goat Cyber client
    Natera logo, Blue Goat Cyber client
    Velico Medical logo, Blue Goat Cyber client
    Medivis logo, Blue Goat Cyber client
    Spiro Robotics logo, Blue Goat Cyber client
    Nova Biomedical logo, Blue Goat Cyber client
    VitalConnect logo, Blue Goat Cyber client
    Intuitive Surgical logo, Blue Goat Cyber client
    bioMérieux logo, Blue Goat Cyber client
    Inogen logo, Blue Goat Cyber client
    Natera logo, Blue Goat Cyber client
    Velico Medical logo, Blue Goat Cyber client
    Medivis logo, Blue Goat Cyber client
    Spiro Robotics logo, Blue Goat Cyber client
    Nova Biomedical logo, Blue Goat Cyber client
    VitalConnect logo, Blue Goat Cyber client
    Christian Espinosa, Founder & CEO

    Reviewed by Christian Espinosa, MBA · Founder & CEO

    Last reviewed

    From a threat to submission evidence

    A connected package, not a pile of reports.

    Each security requirement connects to a threat, a control, and test evidence. Your regulatory team can follow that trail into the submission.

    Fictional example. Not a client report or a prescribed FDA document format.

    Cybersecurity evidence trace
    EXAMPLE
    1. THREAT · TM-04

      An attacker installs unauthorized firmware.

    2. CONTROL · SEC-12

      The device verifies the update signature before installation.

    3. TEST · PT-08

      A modified update is rejected; the authorized update installs.

    4. EVIDENCE

      Threat model → security requirement → test result → submission reference

    The roadmap

    From kickoff to a submission-ready file.

    1. 01

      Kickoff

      Scope · architecture · timeline

      Fixed-fee quote in writing

    2. 02

      Threat model

      Data flows · trust boundaries · attack paths

      Threat model & risk assessment

    3. 03

      SBOM & testing

      Components · vulnerabilities · pen testing

      SBOM & test report

    4. 04

      Submission file

      Traceability · labeling · plans

      Ready for the FDA

    Typical order of work. Steps run in parallel where the schedule allows; the fixed-fee quote lists your exact deliverables.

    Your existing quality system

    Cybersecurity QMS Integration

    Connect device cybersecurity evidence to the way your team works. We help integrate product cybersecurity procedures, records, and responsibilities into your existing quality management system (QMS).

    Premarket documents and handover

    Device-specific cybersecurity documents and the handover explaining how to maintain them belong in the premarket package. Delivering those documents is not the same as revising your organization's quality procedures.

    Separately agreed integration scope

    Procedure revisions, cross-team responsibilities, evidence connections, and implementation support are agreed within your premarket engagement. They are not automatically included in every package.

    Review and revise procedures
    Review your existing cybersecurity procedures and agree revisions for development, threat modeling, security testing, SBOM maintenance, vulnerability handling, and disclosure.
    Connect evidence and decisions
    Map security requirements, risks, controls, and test evidence to your existing quality records. Define owners, approval steps, supplier expectations, and triggers for cybersecurity change reviews.
    Put the process into practice
    Connect postmarket monitoring and incident response to the teams responsible. Walk them through the agreed procedures and a worked example, with record templates and an implementation plan.

    Deliverables are agreed after review: a gap assessment, procedure revisions, record templates, an evidence map, and a prioritized implementation plan. Scope and pricing depend on your existing procedures and the work required.

    Your quality team retains ownership and approval of the QMS. Our scope is product cybersecurity, not full QMS implementation, QMS certification, or verification and validation (V&V).

    See the worked example and request a quote
    Attack surface

    Artifacts a premarket cybersecurity package covers

    The Feb 3, 2026 final premarket cybersecurity guidance and Section 524B(b) define what reviewers expect in your eSTAR cybersecurity attachments. Every artifact below is in scope when we run the full premarket engagement.

    1. 01Architecture views (Global, Multi-Patient Harm, Updateability)
    2. 02Threat model (STRIDE + AAMI TIR57 / SW96)
    3. 03Security risk assessment (IEC 81001-5-1 §7)
    4. 04SBOM (CycloneDX 1.5 / SPDX 2.3) + VEX
    5. 05Cybersecurity controls and traceability matrix
    6. 06Penetration test evidence + retest closure
    7. 07SPDF (Secure Product Development Framework)
    8. 08Cybersecurity labeling for users
    9. 09Postmarket cybersecurity management plan

    Layers shown outermost (top) to innermost (bottom). Dashed rows are part of the surrounding system but out of scope for this view.

    Relevant standards

    Standards FDA premarket cybersecurity package maps to

    Every fda premarket cybersecurity package engagement produces evidence aligned to the regulatory and consensus standards FDA reviewers and notified bodies expect to see - traceable, complete, and ready to drop into your ISO 13485 quality system.

    Featured site-wide
    FDA 2026 Guidance Featured

    FDA Premarket Cybersecurity Guidance (Feb 3, 2026)

    Defines the SPDF, Section 524B submission package, threat modeling, SBOM, security architecture views, and cybersecurity testing every cyber device submission must include.

    Section 524B

    FD&C Act Cyber Device Requirements

    Statutory requirement that every cyber device 510(k), De Novo, PMA, and IDE submission include a complete cybersecurity package or face Refuse to Accept (RTA).

    eSTAR

    Electronic Submission Template

    FDA's mandatory interactive submission template with structured upload slots for each cybersecurity artifact.

    SPDF

    Secure Product Development Framework

    End-to-end secure development lifecycle the FDA expects to see referenced and evidenced in every cyber device submission.

    ANSI/AAMI SW96 Featured

    Medical Device Security Risk Management

    The consensus standard for medical device security risk management - asset, threat, vulnerability, likelihood, severity, and residual risk acceptability.

    ISO 14971 Featured

    Medical Device Risk Management

    Foundational risk management standard. Cybersecurity risk is tied directly to patient-safety risk in the 14971 file.

    ISO 13485 Featured

    Medical Device Quality Management System

    International QMS standard for medical devices. Cybersecurity deliverables are designed to slot into your existing 13485 QMS without parallel paperwork.

    Notable incidents

    Public premarket cybersecurity history

    Recalls, CISA ICS-MA advisories, and disclosed research that shape what reviewers ask about - and what this engagement is built to cover.

    "Blue Goat Cyber helped us navigate our first end-to-end cybersecurity testing for our wearable medical device. Their communication was excellent, their timeline exceeded expectations, and their report helped us achieve FDA clearance without any additional questions. It was a truly seamless experience."
    Anna Norman
    Anna Norman
    VP of Product · InfoBionic.Ai
    MedTech segments

    FDA Premarket Cybersecurity Package for these segments

    See how this service applies to your specific MedTech segment.