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Regulations and guidance

What is the difference between ISO 9001 and ISO 13485?

ISO 9001 sets quality management system requirements for any organisation in any sector; its current edition is ISO 9001:2026. ISO 13485:2016 is the quality management standard for medical devices, written for regulatory purposes. It is based on ISO 9001, adds requirements specific to the device life cycle, with more weight on risk management, traceability and process validation, and omits some of ISO 9001’s generic requirements. Since 2 February 2026, FDA’s device regulation, 21 CFR 820, incorporates ISO 13485 by reference.

Illustration of a seal beside an open evidence folio containing SOP, training and execution records.

1Two standards with different jobs.

ISO 9001 sets out the requirements for a quality management system that any organisation can use. ISO describes it as “suitable for organizations of all sizes and across all sectors”, from manufacturing and services to healthcare, education and government. It covers the context of the organisation, leadership, planning, support, operation, performance evaluation and improvement.¹ The sixth edition, ISO 9001:2026, was published on 16 September 2026 and replaces ISO 9001:2015, which ISO has now withdrawn.¹² ISO says the new edition improves clarity, emphasises quality culture and leadership, separates risks from opportunities and aligns more closely with ISO’s other management system standards.¹

ISO 13485:2016 is the quality management standard for medical devices. Its title ends “Requirements for regulatory purposes”. It is the third edition, published in March 2016 and developed by ISO technical committee ISO/TC 210. ISO last reviewed and confirmed it in 2025, so this version remains current.³ It is meant for “any organization involved in the design, production, installation, and servicing of medical devices and related services”, and suppliers to those organisations can use it too.³ ISO lists it among the sector standards “based on ISO 9001 and adapted to specific sectors”.¹

2Where ISO 13485 differs from ISO 9001.

ISO’s own comparison is short. ISO 9001 is a framework for organisations of any size or sector; ISO 13485 is designed for the medical device industry, “with a focus on regulatory compliance”. It addresses risk management, traceability and process validation, and contains additional requirements for organisations in the device life cycle. In the other direction, “where regulatory requirements are more relevant to the sector, certain generic requirements of ISO 9001 are omitted”.¹ The ISO 13485 page says the standard emphasises “meeting regulatory as well as customer requirements, risk management, and effective process validation more than ISO 9001”.³

AspectISO 9001ISO 13485
Who it is forAny organisation, of any size or sectorOrganisations that design, produce, install or service medical devices, and their suppliers
Current editionISO 9001:2026, sixth edition, September 2026¹ISO 13485:2016, third edition, March 2016, confirmed in 2025³
CommitteeISO/TC 176/SC 2ISO/TC 210
What it aims atCustomer satisfaction and continual improvement of the quality management systemMedical devices that are safe and effective, and that meet regulatory and customer requirements
Added emphasisNone beyond the general frameworkRisk management, traceability and process validation
Relation to the otherThe general standardBased on ISO 9001, with some generic requirements omitted
Use in regulationVoluntary; certification is a choice⁴Incorporated into 21 CFR 820⁵; EN ISO 13485 is harmonised under the EU MDR⁶

3How ISO 13485 became the US device regulation.

On 31 January 2024 FDA issued a final rule that amends 21 CFR 820 to incorporate ISO 13485:2016 by reference, and renamed the regulation the Quality Management System Regulation (QMSR). It took effect on 2 February 2026.⁷ A device manufacturer must now “document a quality management system that complies with the applicable requirements of ISO 13485” and of the rest of Part 820.⁸ Part 820 incorporates two documents: ISO 13485:2016, third edition, and Clause 3 of ISO 9000:2015 for its terms and definitions. ISO 9001 itself is not incorporated.⁵⁹

FDA keeps its own rules beside the standard. Section 820.10(b) ties ISO 13485 clauses to other FDA regulations: unique device identification under Part 830 for Clause 7.5.8, traceability under Part 821 for Clause 7.5.9.1, reporting under Part 803 for Clause 8.2.3, and advisory notices under Part 806.⁸ Design and development, Clause 7.3, applies to class II and class III devices, to class I devices automated with computer software, and to five listed class I devices.⁸ Where a clause of ISO 13485 conflicts with the Federal Food, Drug, and Cosmetic Act or FDA’s regulations, the Act and the regulations control, and the Act’s definitions supersede the standard’s.¹⁰⁹

FDA will not require or issue ISO 13485 certificates, and a certificate “will not exempt a manufacturer from an FDA inspection”. Investigators may now review management reviews, quality audits and supplier audit reports, which the old 820.180(c) kept out of inspection.⁷ If ISO revises ISO 13485, FDA will evaluate the change and, if appropriate, amend the QMSR through rulemaking.⁷

4What the EU Medical Device Regulation expects.

Under Regulation (EU) 2017/745, every manufacturer of devices other than investigational devices must “establish, document, implement, maintain, keep up to date and continually improve a quality management system”, proportionate to the risk class and type of device, covering at least the aspects Article 10(9) lists.¹¹ Article 8 presumes conformity for devices that meet harmonised standards, and says this applies to quality management system requirements too.¹¹ Commission Implementing Decision (EU) 2022/6 of 4 January 2022 added EN ISO 13485:2016 and its amendment EN ISO 13485:2016/A11:2021 to the list of harmonised standards under the MDR, as quality management system standards.⁶

5Which standard a company needs.

A medical device manufacturer works to ISO 13485. Part 820 incorporates ISO 13485, not ISO 9001, and the European version, EN ISO 13485, is harmonised under the MDR.⁵⁶ Part 820 does not apply to manufacturers of components or parts of finished devices, though FDA encourages them to consider its provisions.¹⁰

ISO 9001 suits organisations outside the device sector, and those whose customers ask for a general quality certificate. Certification is voluntary, and it is done by independent certification bodies, not by ISO.⁴ Organisations certified to ISO 9001:2015 will have to move to the 2026 edition within the time frame their certification cycle sets, and ISO advises them to ask their certification body for details.¹

6How it runs in Seal.

In Seal an ISO 13485 quality system runs as connected records: document control, design controls, risk management, CAPA and supplier processes in one record model, alongside the rest of the quality system. For medical devices, requirements link to design outputs, verification and risk controls, and each unit links to the versions and lots it was built from. Seal keeps the design and development file, the medical device file and the record for each device or batch as connected records, whichever names your procedures use.

In design control, the traceability matrix is a view of those links, so a requirement with no linked test is listed as a gap while the design is developed. Your team maps the configured system to the QMSR, ISO 13485 and the other requirements that apply to the device; a workflow existing in Seal does not by itself show conformity.

References

  1. 1ISO 9001:2026, Quality management systems, Requirements, ISO, September 2026. https://www.iso.org/standard/9001 (read 6 November 2026)
  2. 2ISO 9001:2015, Quality management systems, Requirements (withdrawn), ISO. https://www.iso.org/standard/62085.html (read 6 November 2026)
  3. 3ISO 13485:2016, Medical devices, Quality management systems, Requirements for regulatory purposes, ISO, March 2016. https://www.iso.org/standard/59752.html (read 6 November 2026)
  4. 4ISO 9001 explained, ISO. https://www.iso.org/insights/iso-9001-explained (read 6 November 2026)
  5. 521 CFR 820.7, Incorporation by reference, eCFR. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-H/part-820/subpart-A/section-820.7 (read 6 November 2026)
  6. 6Commission Implementing Decision (EU) 2022/6 on harmonised standards for medical devices, EUR-Lex, 4 January 2022. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32022D0006 (read 6 November 2026)
  7. 7Quality Management System Regulation, Frequently Asked Questions, FDA, updated 2 February 2026. https://www.fda.gov/medical-devices/quality-management-system-regulation-qmsr/quality-management-system-regulation-frequently-asked-questions (read 6 November 2026)
  8. 821 CFR 820.10, Requirements for a quality management system, eCFR. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-H/part-820/subpart-A/section-820.10 (read 6 November 2026)
  9. 921 CFR 820.3, Definitions, eCFR. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-H/part-820/subpart-A/section-820.3 (read 6 November 2026)
  10. 1021 CFR 820.1, Scope, eCFR. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-H/part-820/subpart-A/section-820.1 (read 6 November 2026)
  11. 11Regulation (EU) 2017/745 on medical devices, Articles 8 and 10, EUR-Lex, 5 April 2017. https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32017R0745 (read 6 November 2026)

AQuestions and answers

Does an ISO 13485 certificate also cover ISO 9001?

Not by itself. ISO 13485 is based on ISO 9001 but omits some of its generic requirements where regulatory requirements matter more to the device sector, so a system built only to ISO 13485 may not meet every ISO 9001 requirement.

Does ISO 9001:2026 change ISO 13485?

No. ISO 9001:2026 revises the general standard and leaves ISO 13485 as it is. ISO 13485:2016 was reviewed and confirmed in 2025 and remains the current edition, and the QMSR incorporates the 2016 edition by name. FDA says it will evaluate any future revision of ISO 13485 and amend the QMSR through rulemaking if appropriate.

Which devices need design and development controls under the QMSR?

Class II and class III devices, class I devices automated with computer software, and five listed class I devices: tracheobronchial suction catheters, non-powdered surgeon’s gloves, protective restraints, manual radionuclide applicator systems and radionuclide teletherapy sources. Their manufacturers must meet ISO 13485 Clause 7.3.

Does the QMSR apply to component suppliers?

No. Part 820 does not apply to manufacturers of components or parts of finished devices, although FDA encourages them to consider its provisions. ISO says suppliers and other external parties that provide product or quality services to device organisations can use ISO 13485.

Does ISO certify companies?

No. ISO writes and publishes the standards. Certification is done by independent certification bodies, which may themselves be accredited by national accreditation bodies. ISO 9001 certification is voluntary, and FDA neither requires nor issues ISO 13485 certificates.

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