Premarket · Digital Therapeutics

    Full-Service FDA Premarket Cybersecurity for Digital Therapeutics

    End-to-end FDA premarket cybersecurity for prescription DTx - mobile/web app, cloud, prescription auth, and SaMD-aligned threat model and SBOM.

    Last reviewed March 2026 · Reviewed against the FDA Feb 3, 2026 final premarket cybersecurity guidance.

    How this applies to Digital Therapeutics

    Digital therapeutics submissions are often the first time a software-only company encounters FDA's premarket cybersecurity expectations, and the package looks different from a hardware device: there's no firmware, the entire product is the app and the cloud, and the threat model has to focus on prescription integrity, content integrity, and the patient-clinician trust model. Our full-service premarket package for DTx delivers an SPDF, SaMD-tuned threat model, SBOM, pen testing, and architecture views aligned to the FDA 2026 final premarket guidance and to the SaMD-specific reviewer expectations.

    We build the threat model around the prescription pathway (who can issue / fulfill / modify a prescription, and what controls prevent unauthorized intervention), the content-delivery pathway (can a tampered intervention reach a patient?), and the data-collection pathway (PHI handling, sharing with clinicians, research-data export). Mobile app and cloud SBOMs are generated from the build pipeline with VEX. Pen testing exercises the mobile app under instrumented runtime, the cloud APIs for IDOR and cross-tenant leakage (DTx is multi-tenant by default), and the prescription/auth flow for replay and impersonation. Security architecture views include both the global system view and the multi-patient harm view - because DTx, like RPM, serves many patients from one cloud. Package is eSTAR-ready.

    Attack surface

    Layers we exercise in this engagement

    The digital therapeutics system, from the outermost cloud and clinician surfaces down to the device itself. Highlighted layers are exercised by this full-service fda premarket cybersecurity.

    1. 01Clinician web UI Tested
    2. 02Cloud APIs Tested
    3. 03Mobile app (iOS / Android) Tested
    4. 04Push notification path Tested
    5. 05Backend data store Tested

    Layers shown outermost (top) to innermost (bottom). Dashed rows are part of the surrounding system but out of scope for this view.

    How the engagement runs

    Full-Service FDA Premarket Cybersecurity engagement, end to end

    Four phases, fixed fee, scoped to digital therapeutics architecture from kickoff onward.

    1. 01

      Submission gap check

      Existing artifacts mapped against Section 524B(b) and the Feb 2026 guidance; gaps flagged in one document.

    2. 02

      Artifact production

      Threat model, SBOM + VEX, SPDF, architecture views, cybersecurity risk assessment, and labeling produced or upgraded as needed.

    3. 03

      Pen test + evidence

      Independent pen test executed and findings closed before lock so the report ships clean inside the submission.

    4. 04

      eSTAR-ready handoff

      Every artifact delivered in the exact attachment format reviewers expect; we stay on call through the review cycle.

    Common findings

    What we see in Digital Therapeutics full-service fda premarket cybersecurity

    The patterns we hit in this segment, this service, again and again.

    • Prescription/auth flow trusts client-side claims

      App posts 'prescriber-approved' flag; cloud accepts it. Reviewer asks how that's enforced server-side; gap surfaces.

    • Content-delivery integrity not modeled

      Tampered or substituted intervention content not in threat model. Reviewer asks what stops it.

    • Tenant isolation between health-system customers undocumented

      Multi-tenant cloud with shared infra; isolation controls described in code, not evidenced in submission.

    • Mobile-app reverse-engineering not pen-tested

      Pen test treats app as a black-box web client. DTx app should be tested under instrumentation; gap noted.

    "Blue Goat Cyber helped us navigate our first end-to-end cybersecurity testing for our wearable medical device. Their communication was excellent, their timeline exceeded expectations, and their report helped us achieve FDA clearance without any additional questions. It was a truly seamless experience."
    Anna Norman
    Anna Norman
    VP of Product · InfoBionic.Ai
    What you get

    Standard Full-Service FDA Premarket Cybersecurity deliverables

    The same deliverables the parent Full-Service FDA Premarket Cybersecurity service ships with - tuned to your digital therapeutics architecture.

    • Secure Product Development Framework (SPDF)
    • SBOM generation and vulnerability triage
    • Threat modeling aligned to ANSI/AAMI SW96 + ISO 14971
    • eSTAR-ready cybersecurity documentation
    Deliverable preview

    What lands in your eSTAR submission

    Reviewer-format documents ready to drop straight into the cybersecurity attachments of your submission - no reformatting on your side.

    • Secure Product Development Framework (SPDF)
    • SBOM generation and vulnerability triage
    • Threat modeling aligned to ANSI/AAMI SW96 + ISO 14971
    • eSTAR-ready cybersecurity documentation
    Standards

    Standards that apply

    The Digital Therapeutics baseline, plus the call-outs that matter for full-service fda premarket cybersecurity in this segment.

    FDA 2026 Premarket Cyber Guidance
    AAMI SW96
    OWASP MASVS
    OWASP ASVS
    HIPAA Security Rule

    Segment-specific call-outs

    FDA 2026 final premarket guidance + SaMD reviewer expectations

    Software-only products still need full SPDF + threat model + SBOM + pen test + architecture views. No 'lite' version for DTx.

    ANSI/AAMI SW96

    Threat-model framework reviewers will reference for SaMD.

    Honest scoping

    What's not in scope

    We scope tightly on purpose. These items are either out-of-scope by design or belong in a separate engagement - we'll tell you up front, not after kickoff.

    • Quality system buildout (ISO 13485 / QMSR) - separate engagement
    • Clinical or biocompatibility sections of the submission
    • Regulatory filing on your behalf as agent of record
    FAQs

    Full-Service FDA Premarket Cybersecurity for Digital Therapeutics - FAQs

    The questions buyers in this segment actually ask before scoping a full-service fda premarket cybersecurity engagement.

    Related reading

    Go deeper on Digital Therapeutics and premarket

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    Full-Service FDA Premarket Cybersecurity · Digital Therapeutics

    Scope a Full-Service FDA Premarket Cybersecurity engagement for your digital therapeutics program.

    A 30-minute call with a senior engineer who has done this in digital therapeutics before - not a sales rep.