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Regulatory mapping (informative)

This page shows where MedAgentRx touches each regulatory element. It is informative only. Whether a plan meets a regulation is for the manufacturer and the reviewer to decide.

FDA PCCP (final guidance, 4 December 2024)

PCCP component Plan section Checks
Description of Modifications modifications, max_updates, update_frequency PLAN-002, PLAN-004
Modification Protocol: data management data_management DATA-001 to DATA-006
Modification Protocol: re-training modifications[].type PLAN-002, recorded architecture fingerprint
Modification Protocol: performance evaluation performance PERF-001 to PERF-006, LIFE-001, LIFE-002
Modification Protocol: update procedures update_procedures DOC-001; card and release records in the decision ledger
Impact Assessment impact_assessment rendered in the PCCP document

FDA, Health Canada and MHRA published five guiding principles for PCCPs: focused and bounded, risk-based, evidence-based, transparent, and total product lifecycle. The plan's closed list of modifications and fixed intended use keep it focused and bounded. Pre-specified criteria and the locked test set make it evidence-based. The ledger and reports make it transparent. The bio-creep guard and alpha spending cover the lifecycle.

EU AI Act and MDR

Requirement How it is reflected
Article 43(4): pre-determined changes are not a substantial modification The plan file is the record of pre-determined changes; OUTSIDE_PLAN marks anything else
Annex IV point 2(f): description of pre-determined changes in the technical documentation medagentrx render-plan writes that description from the same file the gate runs
Article 10: data governance DATA-002 and DATA-003
Article 15: accuracy PERF-001 to PERF-004
MDCG 2025-6 Predetermined changes are not substantial under the AI Act; MDR significant change is still assessed separately and is outside this tool

What MedAgentRx does not do

  • It does not decide whether a change is significant under the MDR.
  • It does not replace a quality management system, design controls or clinical evaluation.
  • Its output is not itself a regulatory submission.