Healthcare · Clinical AI

The EU AI Act and the MDR, joined up.

Clinical AI is a medical device under the MDR and high-risk under the EU AI Act. Keep one body of evidence for both.

No card · EU-hosted · 5 minutes to a first classification
AssessmentsEmergency triage assistant
Risk classificationArt. 6Done
DPIAGDPR Art. 35Done
FRIAStarted from the DPIA · EU AI Act Art. 27(4)Art. 27In progress
Conformity assessmentArt. 43Not applicable
Written once, reused where the Act allows
Illustrative record · articles are real, the system is not
What clinical leaders ask

Where the two regulations actually pinch.

What we hear

“Our notified body wants EU AI Act conformity referenced in the MDR technical file.”

What the product does

Annex IV sections double as MDR technical-file annexes: one body of evidence.

What we hear

“We're a hospital deploying vendor radiology AI. What do we actually owe?”

What the product does

Only the deployer duties, plus the FRIA where it applies.

What we hear

“The FRIA is new. We don't have a template, and our DPIA isn't a substitute.”

What the product does

The FRIA runs only where required, and its answers feed the DPIA view.

What changes for clinical AI

EU AI Act evidence that also serves the MDR.

01

One evidence base, two regulations

Annex IV sections reused as MDR annexes, carrying the same hash.

02

Conformity through your notified body

The Art. 43 step records which pathway your clinical AI takes.

03

A path for deployers

Hospitals get IFU receipt, oversight, monitoring and worker notification, nothing provider-only.

In practice

Three clinical settings.

Use case 01

A medical-AI vendor selling diagnostic imaging into EU hospitals.

  • Annex IV doubles as the MDR technical-file annex.
  • One sealed IFU package, a sharing token per hospital.
  • Procurement checks the seal at a public verify URL.
Annex IV — Technical DocumentationRecruitment assistant
§1General DescriptionArt. 11
§2System Elements & Development ProcessArt. 11
§3Training, Validation & Testing DataArt. 10
§4Testing & Validation ResultsArt. 15
§5Human Oversight MeasuresArt. 14
§6Risk Management SummaryArt. 9
§7Cybersecurity MeasuresArt. 15
§8Pre-determined Changes & Continuous LearningProvider narrative · to write
Sealedsha256sha256 fingerprint e4d4b64e5aeabf734f6512c3249ff428c83229491c30f20c63c233614049e0227 of 8 filled from the register
Illustrative file · the sections are the builder's own; §8 is always yours to write
Use case 02

A 600-bed hospital deploying vendor radiology and cardiology AI.

  • Provider-only obligations hidden from the dashboard.
  • Vendor IFUs imported, and the oversight plan pre-filled.
  • Where Annex III applies, the deployer's FRIA goes to the clinical-governance committee.
ProviderInstructions for Use
Provider identity and contact details
Intended purpose, characteristics and capabilities
Accuracy, robustness and cybersecurity levels
Known limitations and circumstances of foreseeable misuse
Pre-determined changes to the system and its performance
+ 4 more required elements
SealedOne-time sharing token issued
DeployerRecruitment assistant
One-time sharing token pasted
Imported · 9 elementsImported from the provider’s sealed packageArt. 13Art. 26(1)
Illustrative package · the elements are Article 13(3)’s
Use case 03

A life-sciences group with research AI and clinical-operations AI.

  • R&D provider and deployer obligations kept in separate organisations.
  • Models used solely for scientific research sit outside the Regulation.
  • A group view for the audit committee, a dossier per subsidiary.
Obligation registerDerived by the engine
13obligations applyDeployerHigh

13 obligations apply to a deployer of a high-risk system.

Classify1
Scope & literacy2
Build & document4
Conformity assessment0
Register1
Operate & monitor5
Art. 26(1)Use system per provider's instructions for use
Art. 26(2)Assign human oversight person(s)
Art. 26(5)Monitor operation; suspend & notify on serious risk
Art. 26(9)Use Art. 13 information for the GDPR Art. 35 DPIA
Computed by the engine for one system · switch the role to compare
What clinical teams lean on

Features that fit governance built around the MDR.

Straight answers

EU AI Act for healthcare: questions clinical teams ask

Our AI is already a medical device under the MDR. Does the EU AI Act add a second conformity assessment?

Usually not a separate one. Clinical AI reaches high-risk via the Annex I product route, so EU AI Act conformity travels with the MDR notified-body procedure. Veritome records the pathway at the Art. 43 step.

We are a hospital deploying vendor AI. What do we actually owe?

The Art. 26 deployer duties: use per the instructions, human oversight, logs and worker notification. Where the system is Annex III and you act in a public-services capacity, the Art. 27 FRIA too.

Does patient data change the register?

Yes. Special-category health data brings GDPR Art. 9 and a DPIA into the system's register, and the FRIA's answers sit under the DPIA's Art. 35(7) headings.

Is a DPIA a substitute for the FRIA?

No. The FRIA is its own assessment under Art. 27, though Art. 27(4) lets it build on an existing DPIA. Necessity and proportionality still need the DPIA's own analysis.