Compare FDA CSA guidance and Part 11 scope guidance

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FDA CSA guidancePart 11 scope guidance
AuthorityFDAFDA
Legal weightGuidance & Q&AGuidance & Q&A
StatusFinalFinal
Last verifiedNot yetNot yet
Summary

FDA's risk-based approach to assuring software used in production and quality systems, favouring critical thinking and unscripted testing where risk is lower. Final since September 2025 and updated in February 2026 to align with the QMSR.

FDA guidance on how it applies Part 11. FDA says it will not enforce certain requirements on validation, audit trails, record retention and record copying, and sets criteria for legacy systems. Part 11 remains in effect, and predicate rule requirements still apply.

Lifecycle
  • 13 Sep 2022 Draft guidance published
  • 24 Sep 2025 Final guidance published
  • 3 Feb 2026 Updated and retitled for QMS software
  • 5 Sep 2003 Final guidance issued
SourceOfficial text
Source: FDA. Public domain.
Official text
Source: FDA. Public domain.

These facts are placed side by side from each record. This page does not say which is stricter or whether requirements differ. Read the official texts.