EU MDR Annex XIV Part B + Article 61(11)

EU MDR PMCF & Post-Market Clinical Follow-up Toolkit

EU MDR requires active PMCF — most manufacturers have a plan that would not survive a notified body audit.

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Your PMCF plan will not survive a notified body audit — here is why.

Notified bodies are rejecting PMCF plans that lack specificity. The most common deficiency findings:

  • PMCF plan rejected as insufficient — generic activities with no defined methodology
  • No systematic literature review protocol — ad hoc searches are not acceptable evidence
  • Clinical data gaps not formally identified — no traceability from claims to evidence
  • PMCF and PMS activities disconnected — no integrated post-market clinical system

This toolkit gives you the plan template, the literature protocol, the gap analysis, and the integration guide — everything needed for PMCF that holds up under notified body review.

6 Documents. Complete PMCF system coverage.

From PMCF planning through evaluation reporting and PMS integration.

Document 01

PMCF Plan Template (EU MDR Annex XIV Part B)

Complete PMCF plan aligned with EU MDR Annex XIV Part B requirements. Covers clinical objectives, PMCF activities (literature review, registry studies, surveys), endpoints, timelines, and reporting triggers. Structured to satisfy notified body scrutiny during technical documentation review.

Document 02

PMCF Evaluation Report Template (EU MDR Article 61(11))

Structured report template for documenting PMCF results per Article 61(11) and MDCG 2020-7. Covers analysis methodology, clinical data summary, benefit-risk conclusions, and required updates to clinical evaluation. Designed to integrate directly into your CER update cycle.

Document 03

Literature Search Protocol for PMCF

Systematic review methodology for post-market clinical literature monitoring. Covers database selection (PubMed, Embase, Cochrane), search string construction, inclusion/exclusion criteria, PRISMA flow documentation, and critical appraisal frameworks. Built for repeatability and audit defensibility.

Document 04

Clinical Data Gap Analysis Worksheet

Structured framework for identifying and documenting gaps between your current clinical evidence and EU MDR requirements. Maps clinical claims to supporting data, flags insufficient evidence, and prioritizes PMCF activities to close gaps before notified body review.

Document 05

PMCF Study Protocol Template

Observational study design template for device-specific PMCF studies. Covers study objectives, population selection, endpoints, sample size rationale, data collection procedures, statistical analysis plan, and ethics/regulatory considerations. Aligned with MEDDEV 2.12/2 rev 2 and ISO 14155.

Document 06

Post-Market Surveillance to PMCF Integration Guide

Practical guide for connecting PMS and PMCF activities into a coherent post-market system. Covers data flow from vigilance, complaints, and PSUR into PMCF planning, trigger definitions for PMCF updates, and documentation structure to demonstrate the integrated system notified bodies expect.

Why this toolkit

🔬

Systematic, not ad hoc

The #1 notified body finding on PMCF plans: activities are listed but not systematic. The literature search protocol and study templates give you reproducible, auditable methods that demonstrate scientific rigor.

📋

Gap analysis before submission

Identify clinical evidence gaps before your notified body does. The gap analysis worksheet maps every clinical claim to supporting data and flags exactly where PMCF activities need to focus.

🔗

PMS and PMCF connected

EU MDR requires an integrated post-market system — not isolated activities. The integration guide shows you how to connect PMS signals to PMCF planning with clear data flows and trigger definitions.

$347 vs. the alternative

Regulatory Consultant
$12,000+
40+ hours at $300/hr to build PMCF documentation from scratch
This Toolkit
$347
6 audit-ready documents, instant download

From the teams who built this

We built these templates during our MDR transition for a Class IIb implantable device. Our notified body reviewer specifically commented that the PMCF plan was one of the most complete they had seen. These are the exact frameworks we use at AB Medical for every CE marking submission.

Joshua Millage, CEOAB Medical Technologies

The gap analysis worksheet alone saved us months of back-and-forth with our notified body. We identified three critical evidence gaps before submission that would have triggered a deficiency letter. These templates reflect what reviewers actually expect to see.

Rick, Director of Engineering & RegulatoryAB Medical Technologies

Who this is for

  • RA managers responsible for CE marking renewal under EU MDR
  • Clinical affairs leads managing post-market clinical evidence obligations
  • Companies transitioning from MDD/IVDD to EU MDR that need compliant PMCF documentation
  • Notified body audit preparation teams building defensible technical documentation

Common questions

What is the difference between PMCF and PMS under EU MDR?

Post-Market Surveillance (PMS) is the broad system for collecting and evaluating post-market data — complaints, vigilance, literature, registries. PMCF is the clinical subset: proactive, planned clinical activities to confirm safety and performance throughout the device lifetime. PMS feeds into PMCF, and PMCF results feed back into the clinical evaluation. EU MDR requires both, and notified bodies expect to see how they connect.

What do notified bodies actually look for in a PMCF plan?

Notified bodies look for specificity and scientific rigor. Generic statements like "we will monitor literature" get flagged. They want to see: defined search strings and databases, specific clinical questions tied to your device, measurable endpoints, timelines, sample size rationale for studies, and clear criteria for when PMCF findings trigger a CER update. The templates in this toolkit are structured around these expectations.

Do I need PMCF if my device has a long clinical history under MDD?

Yes. EU MDR Article 61(11) requires PMCF for all devices regardless of clinical history. Even well-established devices need a PMCF plan — though the scope and intensity of activities can be proportionate to risk class and available evidence. A legacy device with extensive clinical data may need a lighter PMCF plan, but "no PMCF needed" is not an acceptable conclusion under MDR.

Is this legal advice?

No. This is a practitioner reference toolkit. Consult your regulatory counsel and notified body for formal compliance opinions specific to your device.

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Build PMCF documentation your notified body can't fault.

Six documents. Instant download. EU MDR Annex XIV Part B + Article 61(11).

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