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    FDA Penetration Testing

    FDA Penetration Testing for Medical Devices

    FDA-grade medical device penetration testing - device, cloud, mobile, and wireless attack surface, reviewer-format report.

    The FDA eSTAR acceptance checklist now treats a missing or off-format pen test report as a Refuse-to-Accept trigger - not a deficiency. Submissions are bouncing before review even starts.

    Penetration testing built specifically for FDA premarket submissions under Section 524B and the February 2026 final premarket cybersecurity guidance. Device, cloud, mobile, and wireless tested - report formatted the way FDA cybersecurity reviewers expect.

    • Section 524B(b)(2)-compliant pen test
    • eSTAR-attachable report format
    • Device, cloud, mobile, BLE/RF coverage
    • Findings mapped to STRIDE threat model
    • Independent third-party testers (documented per FDA Test Report requirement)
    • CVSS scoring + reviewer-ready remediation
    • Retest evidence, unlimited retests included (3-4 rounds typical)

    Free 30-min call · Senior US expert · Mutual NDA before the call

    FDA submissions supported
    250+
    Cybersecurity rejections
    0
    Quote turnaround
    24 hrs

    Last updated

    Blue Goat provided testing on our system for cybersecurity and provided the necessary documentation to add to our regulatory submission. They were very knowledgeable in the re…

    Bernie Lane, Engineer Manager, CSA Medical Inc

    • Intuitive
    • Natera
    • bioMérieux
    • Inogen
    • VitalConnect
    250+FDA medical device pen tests shipped
    100%Pen tests that surfaced at least one finding. We have never returned a clean report
    0FDA cybersecurity rejections on a Blue Goat Cyber pen test report
    FDA Feb 2026 guidance · §V.C

    Tester independence, documented the way reviewers expect

    The FDA Test Report requirement asks for an explicit independence statement. Reviewers check for it before they read findings. Every Blue Goat Cyber report includes it, named oversight included.

    External independence

    Our pen test team has no role in writing your device firmware, cloud code, or mobile app, and never has. No remediation work, no architecture authorship, no source contributions. The independence statement in your report names the team and the boundary.

    Internal independence

    Inside Blue Goat Cyber, the pen test team is structurally separate from any consulting or remediation work we do for you. Oversight sits with our CTO and our VP of Regulatory Affairs, both named in the report so reviewers can trace accountability.

    One fixed fee

    Unlimited retesting until clean

    3 to 4 retest rounds is typical. Some submissions take 20+. One fixed fee covers them all. We do not bill per retest, per finding, or per round.

    • Every closed finding gets re-executed against the original exploit path
    • Retest evidence is appended to the same report your reviewer sees
    • Scope creep that introduces new surfaces is a separate quote, on purpose

    Trusted by medical device teams worldwide

    Intuitive Surgical logo
    bioMérieux logo
    Inogen logo
    Natera logo
    Velico Medical logo
    Medivis logo
    Spiro Robotics logo
    Nova Biomedical logo
    VitalConnect logo
    Lifecycle scope

    What's in your FDA penetration test

    Premarket to postmarket. One senior team owns every cybersecurity artifact the FDA reviewer will open.

    01

    FDA 2026 guidance aligned

    Scoped, executed, and reported against the February 2026 final premarket cybersecurity guidance and Section 524B(b)(1)-(3).

    02

    eSTAR-attachable report

    Report structure drops directly into eSTAR - no reformatting, no missing attachments, no acceptance-checklist surprises.

    03

    Every attack surface in scope

    Device firmware, cloud APIs, mobile apps, Wi-Fi, BLE, and RF - tested independently and reported with separate findings sections.

    04

    Mapped to threat model + 524B

    Each finding traces back to a STRIDE threat and a Section 524B(b) clause so reviewers can follow finding → threat → mitigation → evidence.

    05

    Reviewer-format remediation

    CVSS scoring, exploit details, concrete remediation steps, and retest evidence - formatted the way FDA cybersecurity reviewers expect.

    06

    Fixed fee, unlimited retests

    One quote covers initial test plus retests until every finding is closed and the cybersecurity section is reviewer-ready.

    Common FDA findings

    Top findings we surface in the first week of testing

    Across 250+ FDA pen tests, the same classes of finding repeat. Most are fixable in a sprint - the cost is shipping a report without them flagged.

    Cloud API auth scoped to user, not to device

    Mobile companion apps and clinician portals pass user JWTs that can read any device's telemetry. Multi-tenant isolation fails on the first IDOR probe.

    BLE pairing accepts Just Works in production builds

    Engineering left Just Works enabled for bench testing and the production firmware shipped with it. Trivially MITM-able from across the room.

    Firmware update channel unsigned or signature unchecked

    Update package is signed, but the bootloader skips verification when a debug flag is set - and the debug flag ships enabled. Classic 524B(b)(1) finding.

    Hardcoded service credentials in firmware

    Strings-grep finds MQTT broker creds, S3 access keys, or vendor portal tokens compiled into the binary. Same key across the entire fleet.

    Blue Goat Cyber vs. the alternatives

    What you actually get versus a generic pen test shop or doing it in-house against a regulatory clock.

    Capability Blue Goat Cyber Generic pen test shop In-house
    Senior medical device cybersecurity engineers Every project, US-based Junior pen testers, rotating Hard to hire and retain
    FDA reviewer-format reports eSTAR-attachable, 524B-mapped Raw findings dump Built from scratch each time
    Unlimited retests until closed Included, fixed fee Billed per retest Internal cycle cost
    FDA submission track record 250+, zero cyber rejections Rare medical device experience First submission risk
    Mutual NDA before first call Standard Usually after SOW n/a
    Medical device pen test scope

    What we test in an FDA-aligned penetration test

    What happens after you book the call

    1. 1Day 0

      Mutual NDA + 30-min call

      We sign a mutual NDA before the initial call, then walk through your submission, the FDA findings, and the path to close them.

    2. 2Day 1

      Written strategy + fixed-fee quote

      You receive a point-by-point response strategy mapped to Section 524B and the FDA February 2026 final guidance, plus a fixed-fee quote.

    3. 3Weeks 2-4

      Reviewer-ready response package

      Updated SPDF, SBOM/VEX, threat model, targeted pen test, and cover letter - formatted the way FDA cybersecurity reviewers expect in eSTAR.

    "Blue Goat provided testing on our system for cybersecurity and provided the necessary documentation to add to our regulatory submission. They were very knowledgeable in the requirements, and performed the testing onsite which made the logistics of equipment availability easier for us. The communication was excellent, and they were able to expedite the testing and provide final reports in a very short period of time."
    - Bernie Lane, Engineer Manager, CSA Medical Inc

    Cybersecurity deficiency remediation included

    If the FDA raises a cybersecurity deficiency, we fix it at no additional cost. 250+ FDA submissions, zero cybersecurity rejections to date.

    Mutual NDA before the call

    We sign a mutual NDA before the initial call so you can share device details, architecture, and FDA correspondence freely.

    Fixed-fee quote within 24 hours of the call

    No sales pressure. After the call, you get a concrete written strategy mapped to Section 524B and the FDA February 2026 final guidance.

    Senior US engineers, fixed fee

    Senior-led delivery on every FDA-facing artifact. No offshoring, no hourly billing. Unlimited revisions. Every artifact is eSTAR-ready.

    Common questions

    Christian Espinosa, Founder & CEO of Blue Goat Cyber

    Who you're talking to

    Christian Espinosa, Founder & CEO

    MBA, CISSP · U.S. Air Force Academy graduate · 30+ years in cybersecurity

    Christian leads the senior medical device cybersecurity team behind 250+ FDA submissions, zero cybersecurity rejections. Author of three books including Medical Device Cybersecurity: An In-Depth Guide.

    Need an FDA pen test?

    30-minute call with a senior medical device cybersecurity expert. Fixed-fee scope and quote within 24 hours of the call. eSTAR-ready report, unlimited retests included.

    Replies in 1 business dayMutual NDA firstUS-based senior engineerNo sales pitch