EU IVDR & MDR Periodic Safety Update Report (PSUR)
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EU Periodic Safety Update Report (PSUR) Under MDR & IVDR
If you have a moderate or high-risk device, you already know that your post-market obligations under the EU Medical Device Regulation (MDR) and In Vitro Diagnostic Regulation (IVDR) don’t stop once you’ve achieved CE Marking. These regulations require you to proactively collect and evaluate real-world data to confirm that your device continues to perform safely and effectively. Known as the Periodic Safety Update Report (PSUR), this recurring submission is a critical part of your overall Post-Market Surveillance (PMS) activities.
Quick facts about PSUR Requirements:
- Required in Article 86 of MDR and Article 81 of IVDR
- Essential component of Post-Market Surveillance for moderate- and high-risk devices (Class IIa, IIb, III medical devices and Class C/D IVDs)
- Must be submitted to the Notified Body either annually or biennially, depending on device classification
- Structured according to MDCG 2022-21 guidance
- Supports the ongoing benefit-risk assessment and helps maintain CE certification
- Applies throughout the entire lifecycle of the MD or IVD
- Must be aligned with other technical documentation, including the CER/PER, SSCP (if applicable), and risk management file
How NAMSA Supports Your PSUR Requirements
Preparing a PSUR isn’t just about filling in a template, it’s about demonstrating that your device continues to meet safety and performance expectations in the real world. NAMSA helps manufacturers navigate the complexities of PSUR development with confidence and clarity. Our team understands the regulatory requirements under MDR and IVDR, and we know how to interpret and present your data in a way that satisfies Notified Body expectations. At NAMSA, our regulatory and medical writing teams have supported manufacturers globally in preparing PSURs that are complete, compliant, and ready for review. We will help you develop a PSUR:
- Structuring your PSUR report according to MDCG 2022-21
- Preparing the cover page, executive summary, and device descriptions
- Justifying device groupings and ensuring alignment with technical documentation
- Estimating patient exposure and usage for both single-use and reusable devices
- Compiling and interpreting vigilance data, including serious incidents, trend reporting, field safety corrective actions (FSCAs), and CAPAs, ensuring that each element is clearly documented and traceable
- Integrating general PMCF/PMPF data such as user feedback, complaints, scientific literature, registry data, and public databases, as well as a summary of specific PMCF/PMPF activities including clinical studies and targeted follow-up
- Ensuring consistency across CER/PER, SSCP/SSP, and risk documentation
- Preparing your PSUR for Notified Body review with clarity and traceability
Take the Next Step
Want to learn more about our experience in this area? Wondering how long it will take, how we approach it and how much it will cost?
We Know What Your Notified Body Expects to See
After investing significant time and resources into collecting post-market data, the last thing any manufacturer wants is to receive major findings during a Notified Body review. At NAMSA, we understand exactly what reviewers are looking for and how to avoid the common pitfalls that can delay or derail your submission. Our team brings deep experience working with Notified Bodies across Europe, which means we know how to structure your PSUR for clarity, compliance, and successful review.
What sets NAMSA apart is our multidisciplinary approach. Our regulatory, clinical, and biostatistics experts work together to ensure your PSUR is not only technically accurate but also scientifically sound and strategically aligned with your broader documentation. Whether you need support for a single PSUR or ongoing submissions, we offer flexible solutions tailored to your internal resources and timelines.
We also offer a wider range of services than most regulatory consultancies, including clinical trials, preclinical testing, EU market research, and PMCF/PMPF execution. This integrated approach helps us identify and resolve issues early, before they become costly delays.
Frequently Asked Questions (FAQ)
What is PSUR for medical devices?
A Periodic Safety Update Report (PSUR) is a regulatory document required under the European Medical Device Regulation (MDR), specifically Article 86. It applies to moderate- and high-risk devices—Class IIa, IIb, and III—and is designed to provide a structured, recurring summary of a device’s safety and performance once it is on the market. The PSUR must be submitted to the Notified Body either annually or every two years, depending on the classification of the device. The purpose of the PSUR is to demonstrate that the device continues to meet safety and performance expectations throughout its lifecycle. It includes key information such as sales volumes, patient exposure estimates, serious incidents, corrective actions, trend analysis, and findings from Post-Market Clinical Follow-up (PMCF). The report also reassesses the benefit-risk profile of the device and compares its performance to similar products available on the market.
When do I need to submit my first PSUR
Your first PSUR is typically due one or two years after market placement, depending on the device’s classification. You must have a PMS Plan in place at the time of CE submission, and the PSUR follows based on your device’s risk level.
Low risk devices are exempt from presenting post-market surveillance data?
No, all devices need to do post-market surveillance activities and gather the results in a report. But for low risk devices (class I), you would need to create a PMS report instead of a PSUR.
Do I need to submit the PSUR if my device is no longer being sold but still in use?
Yes. If the device is still in use in the market, and was sold after the date of aplication of the MDR—even if it’s no longer actively sold, you are responsible for monitoring its performance and reporting safety data. The obligation to submit a PSUR continues until the device is fully withdrawn and no longer in circulation.
What if I’m transitioning from MDD to MDR—do I need a PSUR?
Yes. If your device remains on the market during the transition and falls within the applicable risk class, you must prepare and submit a PSUR—even if it was originally certified under MDD. The requirement applies to all devices actively placed on the market after the MDR application date.
Can I group multiple devices in one PSUR?
Yes, but you must justify the grouping based on the benefits to report multiple devices in one report, clearly describe each device included, and assign a leading device to the PSUR. The PSUR must still allow for individual performance and safety assessment.
What tools can I use to monitor trends in adverse events?
Trend analysis can be supported by a strong vigilance system, including regular seraches of public vigilance databases , a complete risk management system establishing the expected severity and frequency of each risk, and statistical methods to detect significant increases. NAMSA can help you define thresholds and observation periods, and interpret trend data for inclusion in your PSUR.
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