FDA QMSR in force: what inspectors can now see
Since 2 February 2026, 21 CFR Part 820 incorporates ISO 13485:2016 by reference. The biggest practical change for many manufacturers is visibility: management review, quality audit and supplier audit reports are no longer exempt from FDA inspection.
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What stays FDA-specific. The regulation keeps requirements beyond ISO 13485, including content requirements for complaint and servicing records, UDI, and labelling and packaging controls, and links to medical device reporting and corrections and removals.
Terminology. The QSR terms design history file, device master record and device history record are no longer defined. Legacy records remain useful, but their content must satisfy the ISO 13485 clauses that now apply.
Four practical steps. Review management review records as if an investigator will read them. Reconcile legacy DHF, DMR and DHR content. Check that complaint records capture the MDR reportability determination. Run a QMSR-style mock inspection.
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