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Is your quality system ready for an MDSAP audit across five markets?

We prepare medical device and IVD manufacturers for MDSAP audits against ISO 13485:2016 and the requirements of the US, Canada, Brazil, Australia and Japan. Readiness depends on the markets you supply, because they set what the audit checks beyond the standard.

Overview

Why does an MDSAP audit find what the ISO 13485 audit did not?

MDSAP audit preparation for medical devices and IVD · MDSAP audit approach (MDSAP AU P0002) · ISO 13485:2016 · requirements of FDA, Health Canada, ANVISA, TGA and MHLW/PMDA

Last updated: October 29, 2026

An MDSAP audit takes ISO 13485:2016 as its base and adds the requirements of every participating market the company supplies, from registration to adverse event reporting. A system certified against the standard alone has not yet been audited against those additions.

  • The scope follows the markets, not the certificate. Under the MDSAP audit approach, the requirements of all participating jurisdictions are included by default; a manufacturer may exclude only the requirements of a market it does not intend to supply.
  • The vigilance procedure covers some markets but not all. The MDSAP grading guideline uses this case as its example: a procedure that meets Canadian and US criteria, an adverse event reported to both, and no report to Australia, where the device is also sold. It is graded against ISO 13485 clause 8.2.3, with direct QMS impact.
  • Design changes are released without checking the notification duty in each market. The audit approach tells the audit team to follow design changes from the design and development process to the question of which changed devices need a notification to which authority.
  • The team expects major and minor. MDSAP grades every nonconformity from 1 to 5; one grade 5 finding or more than two grade 4 findings mean the auditing organization informs the authorities within five working days of the last audit day.

Industries

What this means in your industry

Select an industry

Medical Devices

What applies
MDSAP audit approach on the basis of ISO 13485:2016 plus the requirements of each participating market supplied; in Canada an MDSAP certificate is the QMS evidence for class II, III and IV licenses.
Who audits
An MDSAP-recognized auditing organization. The participating authorities receive the audit report and decide how to use it in their own procedures.

IVD

What applies
The same audit approach applies: it covers the IVD classes of the Australian regulations and Japan's QMS ordinance for in vitro diagnostic reagents, and Canada licenses IVDs as medical devices.
Who audits
The same auditing organization; the WHO prequalification program for in vitro diagnostics takes part in MDSAP as an official observer.

Services

How we support you

Audit scope by market

Which participating markets you supply, in which role (manufacturer, sponsor, marketing authorization holder), and which jurisdictions can be excluded with a justification. Deliverable: a scope statement per site that the auditing organization can use to plan the audit.

MDSAP readiness assessment

A review of your quality management system against the tasks of the seven MDSAP processes and the country-specific requirements of the markets in scope, with each gap linked to the clause or regulation it misses. Deliverable: a gap list per process and market, prioritized by the grade a finding would likely receive.

What it comes down to

MDSAP replaces several audits with one, and it widens that one audit. A recognized auditing organization audits your quality management system once against ISO 13485:2016 and the regulatory requirements of the participating markets you supply. The report then goes to the authorities, which use it in their own procedures.

The audit runs in a fixed order through seven processes: management; measurement, analysis and improvement; design and development; production and service controls, with purchasing audited alongside. Two further processes serve the specific requirements of the participating authorities: device marketing authorization and facility registration, and adverse event and advisory notice reporting.

The cycle runs for three years. The initial audit has two stages, a surveillance audit follows in each of the next two years, and a recertification audit closes the cycle. The authorities require unannounced audits where high grade nonconformities have been found; special audits follow, for example, an extension of scope or a significant complaint.

MarketAuthorityWhat the MDSAP audit is used for
United StatesFDAsubstitute for the routine inspection
CanadaHealth CanadaQMS evidence for class II, III and IV licenses, only MDSAP certificates since January 1, 2019
BrazilANVISAinput to ANVISA's assessment procedures; for class III and IV, which need a GMP certificate before registration, it can take the place of ANVISA's own inspection
AustraliaTGAauditing organizations assess the QMS on behalf of the TGA under the conformity assessment procedures
JapanMHLW, PMDAused in the QMS inspection; PMDA can still inspect on site or ask for documents

For the FDA, the MDSAP report replaces the surveillance inspection, not every inspection: compliance follow-up, for-cause, specific product risk assignment and PMA inspections before and after approval remain. How the FDA itself inspects under the QMSR is set out in our article on compliance program 7382.850.

Every nonconformity is graded from 1 to 5, following GHTF/SG3/N19:2012 as applied in MDSAP. The grade does not fall when the finding is fixed. After the audit, a remediation plan is recommended within 15 calendar days and the evidence for grade 4 and 5 findings within 30; the auditing organization then submits the complete report package to the authorities.

Outside this page: the certification audit under ISO 13485:2016 alone, the notified body audit for the CE mark under MDR and IVDR, and the preparation for an FDA inspection under the QMSR.

Our approach

Our approach

01

Set the scope

A list of the markets in scope with the role of the company in each and the justified exclusions.

02

Assess

A gap list against the MDSAP processes and the country-specific requirements, prioritized by likely grade.

03

Close the gaps

Revised procedures, records and a reporting matrix for the markets in scope.

04

Rehearse

A mock audit in MDSAP sequence with graded findings and time to act on them before the audit date.

05

Respond

A remediation plan within the recommended 15 days and, for grade 4 and 5 findings, evidence within 30.

Common pitfalls

Where projects commonly fail

The ISO 13485 certificate is taken as proof of MDSAP readiness.

The MDSAP audit criteria include the standard and the regulations of each participating market the company supplies; the certificate says nothing about the second part.

Markets are excluded to keep the audit short.

The audit approach allows an exclusion only for a jurisdiction the company does not intend to supply, and the exclusion has to be justified in the audit scope.

One reporting deadline is used for every market.

Annex 3 of the MDSAP audit approach lists the timeframes for adverse event reports and advisory notices per jurisdiction, and they are not the same.

The response to findings starts when the report arrives.

The recommended dates count from the last audit day: a remediation plan within 15 calendar days, the evidence for grade 4 and 5 findings within 30.

A finding is argued down to a lower grade with a quick fix.

Under the grading guideline, the grade does not change as a result of a correction or corrective action; only the auditing organization's appeals process can amend it.

Quality Management & Compliance

Do any of these pitfalls apply to you?

In a first call we assess your situation and say what needs clarifying first in your case. Without obligation, reply usually within one working day.

FAQ

Frequently asked questions

The Medical Device Single Audit Program lets an MDSAP-recognized auditing organization carry out one regulatory audit of a manufacturer's quality management system that satisfies the participating authorities. Members are the TGA (Australia), ANVISA (Brazil), Health Canada, MHLW and PMDA (Japan) and the FDA; the EU, Singapore's HSA, the UK MHRA and the WHO prequalification program for IVDs are official observers.

Sources
  • FDA, Medical Device Single Audit Program (MDSAP), content current as of December 19, 2025: https://www.fda.gov/medical-devices/cdrh-international-affairs/medical-device-single-audit-program-mdsap
  • MDSAP AU P0002.009, MDSAP Audit Approach (revision date 2024-08-06), via FDA, MDSAP Audit Procedures and Forms: https://www.fda.gov/medical-devices/medical-device-single-audit-program-mdsap/mdsap-audit-procedures-and-forms
  • MDSAP AU P0037.001, Guidelines on the use of GHTF/SG3/N19:2012 for MDSAP purposes (2021); MDSAP AU P0027.007, Post-Audit Activities and Timeline Policy (2022); MDSAP AU P0008.008, Audit Time Determination Procedure (2023)
  • FDA, Compliance Program 7382.850, Inspection of Medical Device Manufacturers, implementation date 02/02/2026, Part I.9 and Part III (inspection types): https://www.fda.gov/media/80195/download
  • MDSAP Frequently Asked Questions, version 016 (2017-08-22), FDA: https://www.fda.gov/media/90179/download
  • Health Canada, Notice: Transition Plan for the Medical Device Single Audit Program (MDSAP), December 4, 2015, and page Medical Device Single Audit Program (MDSAP)
  • Canada, Medical Devices Regulations (SOR/98-282), sections 32 and 32.1, Justice Laws Website, current to 2026-09-30
  • ISO 13485:2016, Medical devices, quality management systems, requirements for regulatory purposes

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Regulations & standards considered

  • MDSAP AU P0002.009, MDSAP Audit Approach (audit sequence, seven processes, audit cycle, country-specific requirements, Annex 3 on reporting timeframes per jurisdiction, Annex 5 on acceptable exclusions)
  • MDSAP AU P0037.001, Guidelines on the use of GHTF/SG3/N19:2012 for MDSAP purposes (nonconformity grading 1 to 5)
  • MDSAP AU P0027.007, Post-Audit Activities and Timeline Policy
  • MDSAP AU P0008.008, Audit Time Determination Procedure
  • ISO 13485:2016 (quality management systems for medical devices)
  • Canada, Medical Devices Regulations (SOR/98-282): quality management system certificate for class II, III and IV licenses under sections 32 and 32.1
  • 21 CFR Part 820 (United States)
  • RDC ANVISA 665/2022 (Brazil), Therapeutic Goods (Medical Devices) Regulations 2002, Schedule 3 (Australia), MHLW Ministerial Ordinance No. 169 (Japan)

Have a concrete project?

Briefly outline your situation. We'll respond with an initial assessment, usually within one business day.

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info@theentourage.it

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