FabolaKnowledgeBuilding an evidence strategy

Evidence and validation for medical devices and IVDs

More validation is not automatically better validation.

The question is whether the evidence supports what the product is for and what is said about it.

Fabola translates intended purpose, claims, technology and risk into an evidence strategy: what needs to be demonstrated, with what data, and to what level of confidence.

You can do much of this yourself

The rules are public. So is much of the guidance.

A good evidence strategy normally starts by working from the regulatory requirement towards the study, rather than starting with a study and trying to justify it afterwards.

1. Start with the regulation

For a medical device, look at MDR Article 61 and Annex XIV on clinical evaluation.

For an IVD, start with IVDR Article 56 and Annex XIII. The IVDR structures performance evaluation around three questions:

  • Is there scientific validity?
  • Does the device perform analytically?
  • Does it perform clinically for its intended purpose?

Those questions should determine what evidence you need.

2. Check the MDCG guidance

The European Commission maintains a searchable collection of MDCG guidance explaining how the MDR and IVDR are applied in practice.

Some particularly useful starting points are:

  • MDCG 2020-1 for clinical or performance evaluation of medical device software
  • MDCG 2022-2 for clinical evidence for IVDs
  • MDCG 2020-5 when relying on equivalence
  • MDCG 2020-7 and 2020-8 for post-market clinical follow-up planning and reporting

Not every document will apply to every product. The point is to find the guidance that relates to the claim, technology and evidence question you are dealing with.

3. Find the relevant standards

Standards provide established methods for many parts of verification and validation.

Depending on the device, useful examples include:

  • ISO 14971 for risk management
  • IEC 62304 for medical device software lifecycle processes
  • IEC 62366-1 for usability engineering
  • ISO 14155 for clinical investigations of medical devices
  • ISO 20916 for clinical performance studies of IVDs
  • IEC 81001-5-1 for cybersecurity activities in the health software lifecycle

For IVD analytical performance, CLSI guidelines are also an important source of established study methods. They cover questions such as precision, linearity, interference, method comparison and detection capability.

The European Commission publishes the current lists of harmonised standards under the MDR and IVDR. MDCG 2021-5 also explains how standards, harmonised standards and state of the art fit into the regulatory framework.

4. Work backwards from the claim

Before commissioning a test, validation exercise or clinical study, ask:

  • What claim does this evidence support?
  • Which regulatory or safety requirement does it address?
  • What characteristic are we trying to demonstrate?
  • What would constitute an acceptable result?
  • Why is this method appropriate?
  • How much evidence is enough to support the conclusion?

If those questions cannot be answered, it may be too early to run the study.

Where Fabola comes in

The difficult part is rarely finding another guidance document.

It is deciding which requirements actually apply, what evidence is already available, where the genuine gaps are, and what level of evidence is proportionate.

We help manufacturers build that chain from:

intended purpose → claims → risks → requirements → evidence → acceptance criteria

The result should be evidence that is scientifically credible and regulatorily defensible, without generating studies simply because they feel reassuring.

Further reading

Last reviewed: October 2026

  • MDR Article 61 and Annex XIV. Connects clinical evidence to the device’s intended purpose, characteristics and claims. eur-lex.europa.eu
  • IVDR Article 56 and Annex XIII. Sets out the scientific validity, analytical performance and clinical performance structure. eur-lex.europa.eu
  • MDCG guidance library. The Commission’s maintained collection of MDR and IVDR guidance, including the clinical-evidence documents. health.ec.europa.eu
  • MDCG 2020-1. Clinical evaluation (MDR) and performance evaluation (IVDR) of medical device software. health.ec.europa.eu (PDF)
  • MDCG 2022-2. General principles of clinical evidence for IVDs. health.ec.europa.eu (PDF)
  • Harmonised standards. The Commission’s current lists of harmonised standards under the MDR and IVDR. The references change, so check the live page rather than a static list. health.ec.europa.eu
  • MDCG 2021-5 Rev.1. Standardisation for medical devices: voluntary use of standards, harmonisation, presumption of conformity and state of the art. health.ec.europa.eu (PDF)

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