
MDCG 2025-4: Making Available of Software Apps & Legal Status of App Platform Providers
16 June 2025
MDCG 2019-11 Rev. 1: Qualification and Classification of Software under the MDR & IVDR
23 June 2025Background
Last December the Commission opened a public consultation to evaluate the effectiveness, efficiency, relevance, and added value of the MDR and IVDR. That consultation ran from 12 December 2024 – 21 March 2025.
The above was in response to the challenges implementing the MDR and IVDR (e.g., multiple postponements, EUDAMED delayed), rising costs to comply, and potential reduction of devices available on the European market.
The concerns were enough to bring attention to the Parliamentary level.
Overview of Summary Report
The Commission has published a report summarizing the open consultation feedback: HERE
Overall, 332 responses were submitted. Most respondents were from the EU (86%). And 45% of responses came from economic operators, of which 59 were large-sized companies (250+ employees), 43 were medium (50-250 employees), 32 were small (10-50 employees) and 17 were micro (less than 10 employees).
Respondent perceptions around the MDR
| Question | Percentage in Agreement |
|---|---|
| Has contributed to protecting the health of patients | 46% |
| Has contributed to the competitiveness of the medical device sector | 5% |
| Has contributed to achieving traceability of devices in the EU | 39% |
| Costs for Phase 1 activities are acceptable (e.g., safety and performance data, clinical data, QMS implementation) | 6% |
| Costs for Phase 2 activities are acceptable (e.g., initial certification and the maintenance of certificates) | 4% |
| Costs for Phase 3 activities are acceptable (e.g., post-market obligations, vigilance) | Agreement ranging from 7% to 13% |
| Costs for Phase 4 activities are acceptable (e.g., providing information on devices or certificates) | Agreement ranging from 10% to 15% |
Respondent perceptions around the IVDR
| Question | Percentage in Agreement |
|---|---|
| Has contributed to protecting the health of patients and users | 44% |
| Has contributed to the competitiveness of the IVD device sector | 8% |
| Has contributed to achieving traceability of IVD devices in the EU | 23% |
| Costs for Phase 1 activities are acceptable (e.g., safety and performance data, clinical data, QMS implementation) | 10% or less |
| Costs for Phase 2 activities are acceptable (e.g., initial certification and the maintenance of certificates) | 10% or less |
| Costs for Phase 3 activities are acceptable (e.g., post-market obligations, vigilance) | 10% or less |
| Costs for Phase 4 activities are acceptable (e.g., providing information on devices or certificates) | 10% or less |
What’s Next?
As noted in the Commission’s Have Your Say webpage and in its December 2024 presentation, the Commission will assess the feedback (along with other factors) and adopt changes in Q4 2025.



