Blue Goat CyberBlue Goat CyberSMMedical Device Cybersecurity
    K
    Playbook · AI/ML SaMD

    AI/ML Medical Device PCCP & Cybersecurity Guide

    How to build a Predetermined Change Control Plan for AI/ML SaMD that survives FDA review - and how to threat-model the model itself (poisoning, inversion, adversarial inputs, prompt injection).

    All playbooks
    Updated May 2026 7 pages 16-min read Download PDF

    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.

    PCCP - the three required components

    ML-specific threats to model

    ML-BOM - the bill of materials for your model

    Monitoring - drift and cybersecurity together

    What's in the full PDF

    Want the full 7-page playbook?

    Includes every checklist, table, and template - formatted for printing and sharing.

    Download PDF
    Ready when you are

    Get FDA cleared without the cybersecurity headaches.

    30-minute strategy session. No cost, no commitment - just answers from people who've shipped 250+ submissions.