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    MedTech Cybersecurity · Since 2022

    FDA medical device cybersecurity timeline

    Quick answer

    What are the major FDA medical device cybersecurity milestones?

    The FDA's medical device cybersecurity program runs from a 2013 safety communication, through final premarket guidance in 2014 and postmarket guidance in 2016, the 2022 enactment of Section 524B (effective March 29, 2023), the 2023 final premarket guidance, and the updated 2026 final premarket guidance effective February 3, 2026.

    What applied on a given date?

    Pick a date, such as a submission or clearance date, to see which FDA guidance and rules were in effect.

    Premarket guidance in effect
    February 3, 2026 final guidance (current)
    Postmarket guidance in effect
    December 28, 2016 final guidance (still current)
    Law (Section 524B)
    Section 524B in effect; the FDA actively refuses to accept cyber device submissions that lack 524B content (since October 1, 2023)
    Submission format
    eSTAR required for 510(k) and De Novo submissions

    General reference based on the dates in the table below; not legal or regulatory advice.

    Premarket vs postmarket guidance

    • Postmarket (devices already on the market): the December 28, 2016 final guidance, "Postmarket Management of Cybersecurity in Medical Devices," is still the current FDA postmarket guidance.
    • Premarket (new submissions): the September 2023 final, replaced by the June 2025 final, replaced by the February 3, 2026 final. These cover the postmarket plan a submission must include under Section 524B(b)(1), but they do not replace the 2016 postmarket guidance.
    DateTypeMilestoneSummarySource
    Jun 14, 2013ProgramFDA Safety Communication on Medical Device CybersecurityFirst broad FDA warning on medical device cybersecurity risk; called on manufacturers and HDOs to take action.FDA Safety Communication
    Oct 2, 2014PremarketPremarket Cybersecurity Guidance (final)First final FDA guidance establishing cybersecurity expectations in premarket submissions; introduced threat-modeling and risk-management language.FDA 2014 premarket guidance
    Dec 28, 2016PostmarketPostmarket Cybersecurity Guidance (final)Defined the postmarket cybersecurity lifecycle, CVD program expectations, and the difference between routine and uncontrolled-risk vulnerabilities. Still the current FDA postmarket guidance; the 2023, 2025, and 2026 documents are premarket guidance and did not replace it.FDA postmarket guidance
    Oct 18, 2018PremarketPremarket Cybersecurity Guidance (draft, 2018)Draft introducing 'Tier 1' and 'Tier 2' devices and the concept of a Cybersecurity Bill of Materials (CBOM).FDA 2018 draft guidance
    Dec 29, 2022LawSection 524B added to the FD&C ActConsolidated Appropriations Act, 2023 (Section 3305) added Section 524B, giving FDA explicit statutory authority over cybersecurity in premarket submissions.Public Law 117-328
    Mar 29, 2023LawSection 524B effective dateSection 524B took effect and FDA refuse-to-accept authority attached for cyber devices. FDA held off issuing RTAs based solely on 524B until active enforcement began on October 1, 2023.FDA Refuse-To-Accept policy update
    Sep 27, 2023PremarketPremarket Cybersecurity Guidance (final, 2023)First final guidance under Section 524B; established the Secure Product Development Framework (SPDF) and the seven-section cybersecurity content set.FDA 2023 final guidance
    Oct 1, 2023ProgrameSTAR mandatory for 510(k)FDA-CDRH made eSTAR mandatory for 510(k) submissions, including a structured cybersecurity section.eSTAR program
    Jun 27, 2025PremarketPremarket Cybersecurity Guidance (final, 2025)Final guidance superseding the September 2023 final; refined SPDF, threat-modeling, and SBOM expectations ahead of the February 2026 update.FDA 2025 final guidance
    Oct 1, 2025ProgrameSTAR mandatory for De NovoeSTAR became the required submission format for De Novo classification requests, with the same cybersecurity section as 510(k).eSTAR program
    Feb 3, 2026PremarketPremarket Cybersecurity Guidance (final, 2026) effectiveUpdated final guidance superseding the June 2025 final, which had superseded the September 2023 final; clarifies SPDF expectations, threat-modeling depth, SBOM contents, and labeling.FDA 2026 final guidance

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