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Navigating the FDA QMSR Transition: Insights for Compliance

QSR to QMSR Transition

(5-Part Microlearning Video Series)

Audience: Medical device professionals, quality managers, and compliance teams

Why You Should Care (Yes, You)

The FDA just swapped out its 25-year-old Quality System Regulation (QSR) for the snazzy, ISO 13485-based Quality Management System Regulation (QMSR). The final rule dropped on January 31, 2024, and the clock is ticking toward full enforcement on February 2, 2026 – that’s a two-year timeframe and not a day more. Miss that deadline and you’ll be explaining yourself to an FDA investigator faster than you can say “Form 483.”

Watch time: 3 min

In this video

  • What is QMSR? A wholesale rewrite of 21 CFR Part 820 aligning US CGMP with ISO 13485:2016—plus a few FDA-specific tweaks to keep lawyers happy.
  • Why ISO 13485? Harmonization eliminates duplicate audits, smooths global market entry, and lets FDA leverage an already mature standard.
  • Timeline you can’t ignore:
    • Final rule published – 31 Jan 2024
    • Effective date – 2 Feb 2026 (two-year implementation)
    • Your action plan: gap analysis → remediation → internal audits → management review → sleep better at night

Pro tip: Start training ops and suppliers now—nobody ever complained that they were “too ready” for an FDA inspection.

Watch time: 3 min

What Changed Why It Matters
Structure swapped from subpart-heavy QSR to ISO 13485 clause order Your QMS manual can finally look the same on both sides of the Atlantic
Risk-based thinking baked in FDA expects risk management throughout the product life cycle, not bolted on at the end
Supplemental provisions (complaint handling, traceability, servicing) These FDA-only add-ons keep “US market” nuances intact
Terminology update (e.g., “device master record” ≈ ISO’s “medical device file”) Less glossary juggling for global teams
Documentation flexibility If ISO 13485 lets you, do it digitally, FDA will too – just keep those records easily retrievable

5-Step Action Checklist

  1. Gap analysis – Map every ISO 13485 clause (and FDA extras) to your current procedures
  2. Risk files refresh – Align with ISO 14971; regulators read ISO 13485 and ISO 14971 side by side
  3. Supplier requalification – Ignorance isn’t bliss; they’re in scope.
  4. Training blitz – Quality isn’t a silo sport – get ops, RA/QA, and exec teams speaking QMSR
  5. Mock FDA audit – Fix the warts while the lights are off

Keep the Conversation Going

We invite you and your team to register for one of these courses offered by ELIQUENT Life Sciences for in-depth expansion:

If you find the videos helpful, share this post with a colleague who’s still clinging to the old QSR like it’s vinyl in a Spotify world. Because February 2026 will arrive whether your CAPA log is ready or not.

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