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    • CVD

    MedTech Cybersecurity · Since 2022

    OTA / patch mechanism audit

    OTA Update Questionnaire

    Review risk-based update practices and manufacturer evidence. Architecture choices below are planning examples, not universal FDA requirements. Scores cannot establish compliance, risk acceptance, or submission requirements.

    Christian Espinosa, Founder & CEO, Blue Goat Cyber

    Reviewed by

    Christian Espinosa

    Founder & CEO, Blue Goat Cyber

    Last reviewed October 30, 2026

    Update Integrity & Authenticity

    What stops a malicious or corrupted update from reaching the device.

    Update images are signed with a manufacturer-controlled key

    critical

    Asymmetric signature, not just a checksum.

    Device verifies signature before applying any update

    critical

    Bootloader / OS verifies before commit.

    Signing chain anchored in hardware or measured boot

    high

    Root key in HSM / secure element / TPM.

    Signing keys live in an HSM with documented access controls

    high

    No keys on engineer laptops.

    Update Transport & Distribution

    How updates get from your build system to the device.

    Update server uses mutual TLS or pinned certificates

    high

    Server authenticates the device and vice versa.

    Rollback protection (anti-downgrade) is enforced

    high

    Monotonic version counter checked at boot.

    Delta or differential updates use the same signing + verification path

    medium

    Deltas are a common bypass.

    Update Deployment & Safety

    How updates get applied without harming patients.

    A/B (dual-bank) update with automatic rollback on boot failure

    critical

    Device never bricks on a bad update.

    Update preconditions checked (not in clinical use, battery, network)

    high

    No updates mid-procedure.

    Operator / customer notification and consent workflow exists

    medium

    Per labeling requirements.

    Staged / canary rollout supported

    medium

    Catch field-only issues before fleet-wide.

    Lifecycle & Reporting

    Risk-based lifecycle planning practices; individual controls and architectures are not universally prescribed by the FDA.

    Documented SLAs for critical / KEV-relevant patch deployment

    high

    Aligned to Postmarket Cadence Calculator output.

    Per-device update success / failure telemetry collected

    high

    You can prove fleet status to reviewers.

    Audit log of every update (who, what, when, version, signature)

    medium

    Tamper-evident.

    Key compromise / revocation playbook exists and has been rehearsed

    high

    Including emergency re-signing.

    Cyber update support window stated in labeling (with EoS date)

    medium

    Per §524B and FDA premarket guidance.

    What you'll see after you submit

    OTA mechanism scored across signing, transport, deployment, and lifecycle

    • Planning-priority ratings, not FDA deficiency classifications.
    • Gap list grouped by severity with a concrete remediation per item.
    • Weighted maturity score that down-weights cosmetic items and up-weights signing + rollback safety.
    • JSON export for handing to firmware, cloud, and DevOps owners.

    Common misconceptions

    What teams usually get wrong

    • Myth: TLS to the update server is enough.

      Reality: TLS protects the channel. The FDA expects signature verification of the image itself, plus rollback protection - bytes on the device must be authenticated, not just the transport.

    • Myth: We don't need A/B partitions because we test thoroughly.

      Reality: Field environments differ from labs. A/B partitions are one implementation option. Document recovery and rollback appropriate to the device and clinical risks; the FDA does not universally require dual-bank storage.

    • Myth: Signing keys can live on the build server.

      Reality: Keys on a build server are one CI compromise away from being used to push a malicious update at scale. Consider secure key protection appropriate to the threat model; HSM/KMS and dual-control are examples, not universal FDA-prescribed architectures.

    References & further reading

    Primary sources behind this tool

    1. 1FDA Cybersecurity in Medical Devices (Feb 3, 2026 final premarket guidance) - FDA
    2. 2FDA Postmarket Management of Cybersecurity in Medical Devices (Dec 2016) - FDA
    3. 3IEC 81001-5-1:2021 - Security activities in the product life cycle - IEC
    4. 4NIST SP 800-193 - Platform Firmware Resiliency Guidelines - NIST
    Why this tool is current

    Recent regulatory + supply-chain activity

    Tracked signals that change what reviewers expect. Items move on as new ones land.

    • Jun 30, 2026EOS clock

      RHEL 7 Extended Life Support phase ends - devices on RHEL 7 need a compensating-controls memo

    • Feb 14, 2026Blue Goat research

      AI-letter analysis - 62% of FDA cyber deficiencies cite a missing or stale CVD URL

    • Aug 5, 2025AAMI

      AAMI TIR97:2019 errata published - clarifies postmarket triage SLAs

    Pair with

    The rest of the postmarket program.

    PCCP Builder

    Draft an optional PCCP for manufacturer review; this questionnaire cannot enforce or authorize one.

    Read PCCP Builder

    Postmarket Cadence Calculator

    Patch SLAs that go with your update mechanism.

    Read Postmarket Cadence Calculator

    Controlled vs Uncontrolled Risk Classifier

    Support manufacturer review of remediation urgency using device-specific evidence.

    Read Controlled vs Uncontrolled Risk Classifier

    Postmarket cybersecurity services

    Run vulnerability response with the right SLAs in place.

    Read Postmarket cybersecurity services