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Key Takeaways
- Cybersecurity is a mandatory requirement for medical devices.
- Investors now scrutinize cybersecurity measures.
- Proactive security prevents expensive delays and regulatory problems.
- Build security into products from the initial design stages.
- Simplify security communication; drop the technical jargon.
- Good cybersecurity is a real competitive differentiator.
Part of our Medical device cybersecurity strategy, culture, and lifecycle series. For the full overview, start with Total Product Lifecycle Security for Devices.
Cybersecurity becomes a MedTech differentiator when manufacturers can prove their controls work, explain their patient-safety value, and support them after launch. The FDA's February 3, 2026 guidance sets expectations for security evidence across the total product lifecycle. We recommend building that evidence during development, not assembling it at submission. This reduces avoidable rework and gives investors and hospitals a defensible basis for trust, without promising clearance or procurement approval.
Why this matters
A connected device's security can affect whether clinicians receive reliable information, whether treatment settings remain intact, and whether care continues when a connection fails. Security failures can cause patient harm, expose data, and create financial and reputational damage for manufacturers.
The FDA's Cybersecurity in Medical Devices Final Guidance, dated February 3, 2026, describes expectations for cybersecurity throughout the device lifecycle. Alongside IEC 81001-5-1, ISO 14971, and AAMI TIR57 / ANSI/AAMI SW96:2023, it gives manufacturers a basis for connecting secure development, security risk management, and patient safety.
We see the business argument as straightforward: investors and healthcare providers need evidence that a manufacturer understands and can manage its product's risks. Weak security can hold up regulatory review or block a hospital purchase. Security-by-design helps avoid those obstacles, but only when the design claims have supporting evidence.
Unlocking the Power of Cybersecurity for Medical Device Innovators
At the LSI Europe 2025 conference, a panel discussed how cybersecurity can become a competitive advantage rather than a late-stage obstacle.
The useful distinction is between claiming security and demonstrating it. A manufacturer that can explain its attack paths, show test results, and describe its update process gives investors and buyers something they can evaluate. A presentation that says the device is secure does not.
We recommend using the same underlying evidence for regulatory submissions, investor diligence, and hospital security reviews, then adjusting the explanation for each audience.
The Cybersecurity Mandate: From Optional to Mandatory
Christian Espinosa, Founder and CEO of Blue Goat Cyber, described cybersecurity at the panel as a requirement that can become a deal killer when manufacturers address it too late.
The stakes extend beyond data privacy. Compromise of surgical robots, drug infusion pumps, pacemakers, or defibrillators can affect treatment. Depending on the device and attack, potential harms include paralysis, overdose, or death. Those are risks to assess against the device's actual functions, not claims that every vulnerability produces those outcomes.
In the FDA letters we reviewed for our September 2026 MTEC webinar, one letter raised the same problem nine times across nine controls: the submission described security principles without enough implementation detail to assess them. Password requirements lacked a stated policy; TLS 1.2 claims lacked cipher suites; ECDSA claims lacked the curve or hash function. These were patterns in our reviewed sample, not industry-wide statistics.
This is the part teams skip. A security claim needs a specification, a requirement identifier, and test evidence that addresses that requirement. That connection matters to reviewers and to anyone evaluating whether the manufacturer can deliver what it promises.
Cybersecurity from an Investor’s Perspective
Sean Lavin, MD, an investor at Alpha Lavin Advisors, described growing but uneven awareness among MedTech startups. At the panel, he estimated that awareness had risen from about 5% of companies two years earlier to perhaps 15% or 20%. Those were his observations, not a measured industry adoption rate.
Lavin identified three ways companies learn about cybersecurity: education, pushback from the FDA, or rejection by a hospital. The latter two interrupt plans because the product and commercial schedule may already depend on decisions that now need to change.
We recommend reversing that sequence. Ask intended customers about security requirements while the architecture and development budget can still change. Then make the work visible during diligence:
- Show which security risks could affect the development schedule or patient safety.
- Identify unresolved findings and who owns remediation.
- Explain how the company will monitor vulnerabilities and update fielded devices.
- Distinguish completed testing from planned work.
Investors do not need every protocol detail. They need to know whether security obligations are understood, funded, and supported by evidence.
Defining a “Cyber Device”
Espinosa's explanation of a “cyber device” focused on software and interfaces, including a USB port that could provide connectivity through a wireless adapter. That is a useful starting point, but the statutory scope check needs all three elements.
Under Section 524B(c), a cyber device:
- Includes software, including firmware or programmable logic.
- Has the ability to connect to the internet.
- Contains characteristics that could be vulnerable to cybersecurity threats.
We review indirect connectivity as well as direct connections. A manufacturer should not dismiss a USB, Bluetooth, or other interface simply because the device lacks its own internet connection. Equally, an interface alone is not the entire statutory definition.
Getting this scope decision wrong can leave the development plan without the security work needed for submission and postmarket support.
Cybersecurity and the Marketing Perspective
Claudia Holy, Co-Managing Director of Podymos, urged manufacturers to start with the audience's questions. Investors, hospitals, clinicians, and patients do not all need the same explanation.
We agree, with one condition: the evidence must come before the claim. Marketing should translate demonstrated capabilities, not turn planned controls into present-tense promises.
- Build your security message around the questions investors, hospitals, and patients actually ask.
- Use clear language without removing limits, assumptions, or responsibilities.
- Ask sales teams which security objections delay purchasing decisions.
- Check material claims against the architecture, test results, labeling, and postmarket plans.
A short, accurate answer is more useful than a page of security terminology. It also reduces the chance that sales promises something engineering has not implemented.
Designing for Cybersecurity: An Iterative Process
Espinosa warned that adding security at the end of development creates cost, delays, investor frustration, and weaker designs. We recommend threat modeling early enough to change architecture decisions, then updating it as interfaces and use cases change.
On a Class II wearable we tested, the firmware update bootloader checked a CRC but did not verify a cryptographic signature. We modified one byte in a captured firmware image and replayed it. The device installed the image and rebooted into modified firmware.
See also: What Is MedTech? MedTech vs Medical Device vs Life Sciences, CVSS Scoring for Medical Devices: A Complete Walkthrough, and Medical Device Software Development: A Compliance Guide.
The recommended remediation was specific: sign images with ECDSA P-256, verify the signature in the bootloader before committing the update, protect the public key against writes, and add a monotonic version counter to prevent rollback. This was not a documentation gap. It required changes to the update design and security retesting.
Security work also continues after launch. As Espinosa noted, a vulnerability accepted as low risk can become easier to exploit when a new exploit is published. The risk assessment must respond to that change.
- Build security into the product development lifecycle from the start.
- Integrate secure-development activities with the software lifecycle processes described by the IEC 62304 standard, alongside security-specific practices.
- Keep the software bill of materials current and monitor component vulnerabilities.
- Reassess risk when exploitability changes, and maintain a working path to update fielded devices.
A patch plan is not enough if the device cannot safely receive the patch.
Overcoming the Cybersecurity Jargon Barrier
Espinosa and Holy both challenged the industry's reliance on acronyms and standards as a substitute for explanation. We keep the technical detail in the evidence, then explain its operational meaning.
On a Class II wearable we tested, loss of the RF link caused the device to buffer telemetry silently. A clinician-visible alert appeared only after 30 minutes of continuous loss. Our recommendations included documenting that behavior in labeling and adding a configurable alert threshold for sustained connectivity loss.
That finding gives different audiences a concrete question. Engineering needs to define the failure behavior. Clinicians need to know when missing telemetry becomes visible. A hospital buyer needs to understand how the device behaves when connectivity fails.
- Lead with what the control or failure means in practice.
- Tailor the explanation to investors, clinicians, patients, or technical reviewers.
- Keep protocol names, configurations, and test evidence available for those who need them.
- State remaining risks plainly.
Plain language should make the engineering understandable, not hide uncertainty.
Cybersecurity as a Competitive Advantage
Lavin's investment perspective points to a useful opportunity: manufacturers that can answer security questions with evidence are better prepared for diligence than those still treating security as future work.
We would not promise faster adoption from cybersecurity alone. Clinical value, workflow fit, price, and other purchasing factors still matter. But a credible security program can reduce avoidable objections and help buyers assess whether the manufacturer can support the device over its service life.
The advantage comes from work that is difficult to fake:
- Security requirements connected to threats and patient-safety risks.
- Penetration testing that covers the actual interfaces and attack paths.
- Remediation supported by retest evidence.
- Customer-facing instructions for secure configuration, updates, and end-of-life handling.
- A postmarket process with assigned owners and a usable disclosure channel.
Present those capabilities as evidence of product quality and support readiness. Explain what they do for providers and patients. Do not ask customers to accept reassurance in place of results.
Conclusion: Embracing Cybersecurity for MedTech Success
The LSI Europe 2025 panel's message remains practical: understand the user's requirements, design security into the product, and explain the value clearly.
We would add one test for leadership: can the company trace its most important security claims to requirements, test results, and postmarket responsibilities? If not, improve that evidence before expanding the marketing message.
Cybersecurity becomes a differentiator when the manufacturer can show how it protects treatment, manages vulnerabilities, and supports customers after launch. That is a stronger foundation for investor and healthcare-provider trust than a claim of compliance alone.
To learn how Blue Goat Cyber can help your MedTech company work through cybersecurity requirements, schedule a Discovery Session.
How Blue Goat approaches this
We support medical device cybersecurity from initial design through postmarket activities. Our work includes threat modeling, security risk management, penetration testing, and regulatory submission support. We connect findings to design requirements and patient-safety risks so engineers and leadership can act on them.
Our engineers, many with prior US military red team experience, translate regulatory expectations into specific engineering tasks and submission evidence aligned with current FDA guidance.
Should the FDA raise cybersecurity deficiencies after a submission we support, we resolve them at no additional cost. That commitment supports the response process; it does not guarantee clearance or a particular review outcome.
Learn more about our specialized support for FDA Premarket Cybersecurity Services.
Related reading: Market Intelligence & Cybersecurity: A 2026 Playbook for MedTech Leaders, Medical Device Cybersecurity Myths: A 2026 Playbook for MedTech Leaders, Traditional vs Medical Device Cybersecurity: A 2026 Playbook for MedTech Leaders, IDS/IPS Agents on Medical Devices: A 2026 Playbook for MedTech Leaders, What Investors Ask Medical Device Founders About Cybersecurity.
FAQ
What is considered a 'cyber device' by the FDA?
Under Section 524B(c), a cyber device includes software, can connect to the internet, and contains characteristics that could be vulnerable to cybersecurity threats. We assess indirect connectivity too. A USB port or companion-device connection warrants review, but an interface alone is not the complete definition.
How does cybersecurity impact medical device market approval?
Inadequate cybersecurity controls or evidence can trigger FDA questions, delay review, or prevent authorization. The February 3, 2026 premarket cybersecurity guidance describes the FDA's expectations. We recommend addressing those expectations during development rather than waiting for submission review.
Why is cybersecurity important to MedTech investors?
Cybersecurity shows whether a company understands its product risks and support obligations. Investors can use security evidence to assess potential rework, regulatory delays, breaches, and postmarket costs. Strong controls reduce risk; they do not eliminate it.
When should cybersecurity be integrated into medical device development?
At the beginning, while threat modeling can still influence architecture and interface decisions. Adding controls late can require redesign, delay submission, and leave a less secure product. We keep security activities active throughout development and postmarket support.
Does the FDA prioritize cybersecurity for all medical devices?
The FDA considers cybersecurity where it can affect device safety and effectiveness, with lifecycle expectations reflecting connected health-system risks. The specific statutory obligations under Section 524B apply to devices meeting the cyber-device definition. We assess scope and risk rather than assuming every device needs identical controls.
How can MedTech companies simplify cybersecurity communication?
Explain what a control does, what evidence supports it, and what risk remains. Tailor the explanation to the audience: investors need to understand business exposure, healthcare providers need operational details, and patients need clear instructions. Keep technical evidence available without making every reader decode it.
About the author

Christian Espinosa, MBA · Founder & CEO, Blue Goat Cyber
U.S. Air Force Academy graduate and veteran with 30+ years in cybersecurity. Founded Alpine Security in 2014 (acquired 2020), then Blue Goat Cyber in 2022. Has supported 275+ medical devices, with no cybersecurity-related rejections to date. Author of three books including The Smartest Person in the Room. Ironman triathlete and mountaineer.
Sources & references
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- ISO- ISO
