Why this matters
AI/ML-enabled SaMD presents unique cybersecurity threats - the model itself is an asset that can be attacked. The FDA's 2026 cybersecurity guidance specifically calls out poisoning, inversion, adversarial inputs, and prompt injection. At the same time, the FDA's PCCP framework lets you pre-authorize model updates without a new submission - but only if the plan is precise, bounded, and verifiable.
Key takeaway: A PCCP without a cybersecurity dimension is incomplete. Every modification protocol step needs a security check - not just performance metrics.
