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Per Section 524B, a device that (1) includes software validated/installed/authorized by the sponsor, (2) has the ability to connect to the internet, and (3) contains technological characteristics that could be vulnerable to cybersecurity threats.
Why it matters
If your device meets all three criteria, the full premarket cybersecurity package is mandatory.
Regulation & Statute
Food, Drug, and Cosmetic Act(FD&C Act)
The federal statute that gives FDA its authority over food, drugs, devices, and cosmetics in the United States.
Regulation & Statute
HIPAA
Health Insurance Portability and Accountability Act. Sets US privacy and security rules for protected health information (PHI) handled by covered entities and business associates.
Why it matters
Cloud-connected devices that touch PHI may pull manufacturers into HIPAA business-associate obligations.
Regulation & Statute
PATCH Act
Protecting and Transforming Cyber Health Care Act - the legislative vehicle that became Section 524B inside the Consolidated Appropriations Act, 2023.
Regulation & Statute
Protected Health Information(PHI)
Individually identifiable health information protected under HIPAA.
Regulation & Statute
Quality Management System Regulation(QMSR)
FDA's modernized 21 CFR Part 820, effective February 2, 2026, which harmonizes US quality system requirements with ISO 13485:2016.
Why it matters
Cybersecurity activities need to be embedded in design controls and risk management under the QMSR framework.
Regulation & Statute
Section 524B
Section of the Federal Food, Drug, and Cosmetic Act added by the Consolidated Appropriations Act of 2023, granting FDA explicit authority to require a complete cybersecurity package in every cyber-device premarket submission.
Why it matters
Cybersecurity is now a federal statutory requirement for premarket submissions - not a best practice. Missing pieces can trigger Refuse To Accept (RTA).
7 terms
FDA Guidance
FDA Guidance
Additional Information (AI) Letter
FDA correspondence sent during review listing deficiencies the sponsor must address before clearance. Different from the AI in 'AI/ML'.
Why it matters
Cybersecurity AI-letter responses are often the difference between clearance and a multi-month delay.
FDA Guidance
eSTAR
FDA's interactive PDF submission template. Mandatory for 510(k) (since Oct 2023) and De Novo (since Oct 1, 2025). Has structured upload slots for the cybersecurity package.
FDA Guidance
FDA AI/ML Lifecycle Guidance
FDA's evolving framework for AI/ML-enabled device software, including Predetermined Change Control Plans (PCCPs) and Good Machine Learning Practices.
FDA Guidance
FDA Postmarket Cybersecurity Guidance (2016)
FDA guidance on managing cybersecurity vulnerabilities and exploits in marketed and distributed medical devices, including the controlled-vs-uncontrolled risk framework.
FDA Guidance
FDA Premarket Cybersecurity Guidance (Feb 2026)
FDA's final premarket cybersecurity guidance, effective February 3, 2026. Defines the seven-section cybersecurity submission format reviewers enforce at Technical Screening.
Why it matters
Operationalizes Section 524B. Missing a required section can trigger an RTA before the 180-day clock starts.
FDA's mechanism for getting non-binding written feedback on submission strategy, study design, or specific cybersecurity questions before filing.
Why it matters
A Pre-Sub is the cheapest way to validate a cybersecurity approach before committing to a full submission.
FDA Guidance
Refuse To Accept(RTA)
An administrative hold FDA issues when a 510(k) or De Novo submission is missing required elements. The 180-day review clock does not start until RTA is cleared.
Why it matters
Cybersecurity gaps are now a top RTA driver. Most are avoidable with a complete SPDF and threat model.
11 terms
Submission & Pathway
Submission & Pathway
510(k) Premarket Notification
Submission demonstrating that a device is substantially equivalent to a legally marketed predicate device. Most Class II devices clear via 510(k).
Submission & Pathway
Breakthrough Device Designation
FDA program offering priority review and sprint-style FDA engagement for devices that provide more effective treatment for life-threatening or irreversibly debilitating conditions.
Submission & Pathway
De Novo Classification
Pathway for novel low-to-moderate-risk devices with no valid predicate. Creates a new classification regulation when granted.
Submission & Pathway
Device Class (I, II, III)
FDA risk-based classification. Class I = low risk (most exempt), Class II = moderate risk (typically 510(k)), Class III = high risk (typically PMA).
Submission & Pathway
Humanitarian Device Exemption(HDE)
Pathway for devices intended to treat or diagnose conditions affecting fewer than 8,000 patients per year in the US.
Submission & Pathway
Investigational Device Exemption(IDE)
FDA mechanism allowing an unapproved device to be used in a clinical study to collect safety and effectiveness data.
Submission & Pathway
Pre-Submission
Type of Q-Submission used to obtain FDA feedback on testing plans, regulatory strategy, or specific cybersecurity questions before filing.
Submission & Pathway
Predicate Device
A legally marketed device used as the basis for substantial equivalence in a 510(k) submission.
Submission & Pathway
Premarket Approval(PMA)
Most stringent FDA pathway, required for Class III devices. Demands clinical data demonstrating safety and effectiveness.
Submission & Pathway
Software as a Medical Device(SaMD)
Software intended to be used for medical purposes that performs those purposes without being part of a hardware medical device.
Submission & Pathway
Software in a Medical Device(SiMD)
Software that is integral to or controls a hardware medical device.
14 terms
Standards (AAMI/ISO/IEC/NIST)
Standards (AAMI/ISO/IEC/NIST)
AAMI SW87
Standard for application of quality management system concepts to medical device data systems.
Standards (AAMI/ISO/IEC/NIST)
AAMI TIR57
AAMI TIR57:2016 (R2023) - Principles for Medical Device Security – Risk Management. Predecessor and companion to SW96.
Standards (AAMI/ISO/IEC/NIST)
AAMI TIR97
AAMI TIR97:2019 - Principles for medical device security – Postmarket risk management for device manufacturers.
Standards (AAMI/ISO/IEC/NIST)
ANSI/AAMI SW96
ANSI/AAMI SW96:2023 - Standard for Medical Device Security – Security Risk Management. The current consensus standard reviewers expect.
Standards (AAMI/ISO/IEC/NIST)
IEC 60601 series
Family of standards covering basic safety and essential performance of medical electrical equipment.
Standards (AAMI/ISO/IEC/NIST)
IEC 62304
International standard for medical device software lifecycle processes. Defines software safety classes A, B, and C.
Standards (AAMI/ISO/IEC/NIST)
IEC 81001-5-1
International standard for security activities in the health software lifecycle. The cybersecurity counterpart to IEC 62304.
Standards (AAMI/ISO/IEC/NIST)
ISO 13485
International QMS standard for medical device manufacturers. The QMSR (effective Feb 2, 2026) harmonizes 21 CFR Part 820 with ISO 13485:2016.
Standards (AAMI/ISO/IEC/NIST)
ISO 14971
International standard for risk management of medical devices. The framework cybersecurity risk management plugs into.
Standards (AAMI/ISO/IEC/NIST)
ISO/IEC 27001
International standard for an information security management system (ISMS). Common for the manufacturer's enterprise side.
Standards (AAMI/ISO/IEC/NIST)
NIST Cybersecurity Framework(NIST CSF)
Voluntary risk-based framework organized around six functions (Govern, Identify, Protect, Detect, Respond, Recover).
Standards (AAMI/ISO/IEC/NIST)
NIST SP 800-30
Guide for conducting risk assessments. Useful baseline for IT-side risk methodology, complementary to AAMI SW96 on the device side.
Standards (AAMI/ISO/IEC/NIST)
NIST SP 800-53
Catalog of security and privacy controls for federal information systems. Often referenced for cloud-connected device backends.
Standards (AAMI/ISO/IEC/NIST)
UL 2900 series
UL standards for software cybersecurity for network-connectable products, including UL 2900-2-1 specific to medical devices.
14 terms
Threat Modeling & Risk
Threat Modeling & Risk
Attack Surface
Sum of all points where an unauthorized user can attempt to enter, extract data from, or interact with a device or system.
Threat Modeling & Risk
Attack Tree
Tree-structured diagram of how an attacker might achieve a specific goal, with nodes representing attack steps or sub-goals.
Threat Modeling & Risk
Controlled vs Uncontrolled Risk
FDA postmarket framework distinguishing 'controlled' (acceptable residual) from 'uncontrolled' risk. Uncontrolled risk requiring action triggers reporting and remediation timelines.
Threat Modeling & Risk
Data Flow Diagram(DFD)
Diagram showing how data moves through a system, including processes, data stores, external entities, and trust boundaries.
Threat Modeling & Risk
DREAD
Legacy threat-rating method (Damage, Reproducibility, Exploitability, Affected users, Discoverability). Largely superseded by CVSS for scoring.
Threat Modeling & Risk
MITRE ATT&CK
Globally accessible knowledge base of adversary tactics, techniques, and procedures (TTPs). Useful for threat modeling and detection engineering.
Threat Modeling & Risk
MITRE CAPEC
Common Attack Pattern Enumeration and Classification - catalog of common attack patterns used to model threats.
Threat Modeling & Risk
MITRE CWE
Common Weakness Enumeration - community-developed list of common software and hardware weakness types.
Threat Modeling & Risk
PASTA
Process for Attack Simulation and Threat Analysis - risk-centric, seven-stage threat modeling methodology.
Threat Modeling & Risk
Patient Harm Linkage
Discipline of tracing each cybersecurity threat to a possible patient-safety consequence - the bridge between cyber risk and ISO 14971 risk.
Threat Modeling & Risk
Secure Product Development Framework(SPDF)
Lifecycle process for designing, building, and maintaining secure products. Required as a documented framework in FDA premarket submissions.
Threat Modeling & Risk
STRIDE
Threat categorization framework: Spoofing, Tampering, Repudiation, Information disclosure, Denial of service, Elevation of privilege.
Threat Modeling & Risk
Threat Model
Structured analysis of a system identifying assets, trust boundaries, threats, and mitigations. Required artifact in FDA premarket submissions.
Threat Modeling & Risk
Trust Boundary
Line in a system architecture across which the level of trust changes. Common locations for security controls and threat enumeration.
10 terms
SBOM & Supply Chain
SBOM & Supply Chain
Common Platform Enumeration(CPE)
NIST identifier scheme for IT products and platforms. Used to map components to vulnerabilities in the NVD.
SBOM & Supply Chain
CycloneDX
OWASP-maintained SBOM standard widely used in MedTech. Supports SBOM, VEX, and machine-learning bill of materials.
SBOM & Supply Chain
Minimum Elements for an SBOM (NTIA)
NTIA-defined baseline data fields for any SBOM: supplier, component name, version, unique identifier, dependency relationship, author, and timestamp.
SBOM & Supply Chain
Package URL(purl)
Standardized URL format for identifying software packages across ecosystems (npm, PyPI, Maven, etc.). Common identifier in SBOMs.
SBOM & Supply Chain
Software Bill of Materials(SBOM)
Machine-readable inventory of software components, dependencies, and metadata used in a product. Required for cyber-device premarket submissions.
SBOM & Supply Chain
Software Identification Tag(SWID)
ISO/IEC 19770-2 tags identifying installed software. One of the SBOM-compatible identifier formats.
SBOM & Supply Chain
SPDX
ISO/IEC 5962 SBOM specification maintained by the Linux Foundation.
SBOM & Supply Chain
Supply Chain Risk Management(SCRM)
Discipline of identifying, assessing, and mitigating risks from third-party software, firmware, hardware, and services in the device supply chain.
SBOM & Supply Chain
Third-Party / OTS Component
Off-the-shelf software, firmware, or hardware integrated into the device that the manufacturer did not author. Subject to FDA documentation expectations.
SBOM & Supply Chain
Vulnerability Exploitability eXchange(VEX)
Companion artifact to an SBOM that states whether known vulnerabilities are actually exploitable in the product (status: not_affected, affected, fixed, under_investigation).
9 terms
Testing & Validation
Testing & Validation
Boundary Analysis
Security testing focused on inputs and behaviors at the edges of valid input ranges, often combined with fuzzing.
Testing & Validation
Dynamic Application Security Testing(DAST)
Testing of a running application by sending crafted inputs to find runtime vulnerabilities.
Testing & Validation
Fuzz Testing
Automated testing technique that supplies malformed or unexpected inputs to find crashes, hangs, or memory-safety bugs. Expected for protocol parsers and exposed interfaces.
Testing & Validation
Penetration Test
Authorized simulated attack on a device or system to find exploitable vulnerabilities. Required testing artifact in FDA cybersecurity submissions.
Defined points at which a manufacturer stops shipping (EOL) or supporting (EOS) a product. Cybersecurity expectations include planning and customer notification well before EOS.
Postmarket & Lifecycle
Incident Response(IR)
Coordinated process to detect, contain, eradicate, and recover from a cybersecurity incident.
Postmarket & Lifecycle
ISO/IEC 29147
International standard for vulnerability disclosure processes.
Postmarket & Lifecycle
ISO/IEC 30111
International standard for vulnerability handling processes inside an organization.
Postmarket & Lifecycle
Patch Management
Process for identifying, testing, releasing, and tracking software updates to remediate vulnerabilities and bugs over a device's supported life.
Postmarket & Lifecycle
Postmarket Cybersecurity Monitoring Plan
Documented plan describing how the manufacturer monitors for new vulnerabilities and threats affecting marketed devices, and how decisions get made.
Postmarket & Lifecycle
Product Security Incident Response Team(PSIRT)
Team responsible for receiving, triaging, and responding to security issues affecting an organization's products.
6 terms
AI/ML Devices
AI/ML Devices
Adversarial Input
Crafted input designed to cause an ML model to misclassify or behave incorrectly while appearing normal to humans.
AI/ML Devices
Good Machine Learning Practice(GMLP)
Set of guiding principles for the development of AI/ML medical devices, jointly published by FDA, Health Canada, and the UK MHRA.
AI/ML Devices
Machine Learning Bill of Materials(ML-BOM)
Inventory of model artifacts, datasets, and dependencies - a CycloneDX extension applicable to AI/ML medical devices.
AI/ML Devices
Model Drift
Degradation of model performance over time as real-world data diverges from training data. A key postmarket monitoring concern for AI/ML devices.
AI/ML Devices
Model Poisoning
Attack in which an adversary injects malicious data into model training to degrade accuracy or insert backdoors.
AI/ML Devices
Predetermined Change Control Plan(PCCP)
FDA mechanism allowing pre-authorized modifications to AI/ML devices without a new submission, provided the changes follow the documented plan.
11 terms
EU & Global
EU & Global
CE Mark
Conformity marking required for devices placed on the EU market under MDR/IVDR.
EU & Global
EU Cyber Resilience Act(CRA)
EU regulation imposing cybersecurity requirements on products with digital elements. Medical devices are largely carved out, but the interaction with MDR matters.
EU & Global
EU In Vitro Diagnostic Regulation(EU IVDR)
Regulation (EU) 2017/746 governing in vitro diagnostic devices in the EU.
EU & Global
EU Medical Device Regulation(EU MDR)
Regulation (EU) 2017/745 governing medical devices placed on the EU market. Annex I, Section 17 contains the IT security and software requirements.
EU & Global
Health Canada
Canadian medical-device regulator. Publishes premarket cybersecurity guidance broadly aligned with FDA.
EU & Global
IMDRF
International Medical Device Regulators Forum. Publishes harmonized guidance, including 'Principles and Practices for Medical Device Cybersecurity'.
EU & Global
MDCG 2019-16
Medical Device Coordination Group guidance on cybersecurity for medical devices under the EU MDR/IVDR.
EU & Global
NIS2 Directive
EU directive on measures for a high common level of cybersecurity across the Union. Touches healthcare operators that may use medical devices.
EU & Global
PMDA
Pharmaceuticals and Medical Devices Agency - Japanese regulator with cybersecurity expectations referencing IMDRF guidance.
EU & Global
TGA
Therapeutic Goods Administration - Australian medical-device regulator. Has its own cybersecurity guidance.
EU & Global
UKCA
United Kingdom Conformity Assessed marking - UK equivalent of CE marking for the GB market.
10 terms
Cryptography & Identity
Cryptography & Identity
Code Signing
Cryptographic signature applied to firmware or software so that a device or system can verify authenticity and integrity before installation.
Cryptography & Identity
FIPS 140-2 / 140-3
US federal standards for cryptographic modules. Often referenced for cloud-connected device backends.
Cryptography & Identity
Hardware Root of Trust
Tamper-resistant hardware element (TPM, secure element, HSM) that provides the foundation for secure boot, attestation, and key storage.
Cryptography & Identity
Key Management
Lifecycle of cryptographic keys: generation, distribution, storage, rotation, revocation, and destruction.
Cryptography & Identity
Multi-Factor Authentication(MFA)
Authentication that requires two or more independent factors (something you know, have, or are).
Cryptography & Identity
Mutual TLS(mTLS)
TLS variant requiring both client and server to present X.509 certificates. Common for device-to-cloud authentication.
Cryptography & Identity
Post-Quantum Cryptography(PQC)
Cryptographic algorithms resistant to attack by large-scale quantum computers. NIST has standardized initial PQC algorithms; long-lived devices need a migration plan.
Cryptography & Identity
Public Key Infrastructure(PKI)
System of certificate authorities, certificates, and revocation that binds public keys to identities.
Cryptography & Identity
Secure Boot
Boot process that cryptographically verifies firmware/software signatures before execution, establishing a root of trust.
Cryptography & Identity
Transport Layer Security(TLS)
Cryptographic protocol providing confidentiality and integrity for network communications. TLS 1.2+ is the floor for medical device cloud links.
16 terms
Core Concepts
Core Concepts
Common Vulnerabilities and Exposures(CVE)
Standardized identifier for publicly known cybersecurity vulnerabilities. Issued by CVE Numbering Authorities (CNAs).
Core Concepts
Common Vulnerability Scoring System(CVSS)
Open framework for scoring vulnerability severity (Base, Temporal, Environmental). FDA expects CVSS scoring for vulnerabilities, plus medical-device context.
Core Concepts
Covert Channel
Unintended communication path that allows information to move in violation of policy or controls.
Core Concepts
Defense in Depth
Layered security strategy in which multiple controls protect against a given threat so that failure of one does not compromise the system.
Core Concepts
Essential Performance
IEC 60601 concept identifying device performance whose loss or degradation beyond a defined limit results in unacceptable risk.
Core Concepts
Exploit Prediction Scoring System(EPSS)
Data-driven estimate of the probability that a CVE will be exploited in the wild within the next 30 days.
Core Concepts
Known Exploited Vulnerabilities Catalog(KEV)
CISA-maintained catalog of vulnerabilities known to be actively exploited. Useful prioritization input for postmarket monitoring.
Core Concepts
Least Privilege
Principle that every component, user, and process should operate with the minimum permissions necessary.
Core Concepts
Memory Safety
Property of code that prevents access to memory in unintended ways. Lack of memory safety is the root cause of a large share of CVEs.
Core Concepts
National Vulnerability Database(NVD)
NIST-maintained database that enriches CVE entries with CVSS scores, CWE mappings, and CPE identifiers.
Core Concepts
OWASP Top 10
Industry-standard list of the most critical web application security risks. The Mobile and API Top 10 lists are also frequently cited.
Core Concepts
Secure by Design
CISA-promoted principle that security must be a foundational property - designed in from the start rather than bolted on.
Core Concepts
Secure Coding Standards
Language- and platform-specific guidance (e.g., CERT C, MISRA) for writing software that resists common security defects.
Core Concepts
Secure Software Development Framework(NIST SSDF)
NIST SP 800-218 - set of practices for integrating security into the software development lifecycle. Maps cleanly to FDA SPDF expectations.
Core Concepts
Side-Channel Attack
Attack that exploits indirect physical or behavioral characteristics (timing, power, EM emissions) to extract secrets.
Core Concepts
Zero Trust Architecture
Security model that assumes no implicit trust based on network location. Every request is authenticated, authorized, and continuously validated.
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