MDR Articles 83-86

Post-market surveillance, PSUR and PMCF

Under the MDR, post-market surveillance is a continuous system proportionate to the risk class. The reporting output differs by class - a PMS report for Class I, a periodic safety update report (PSUR) for higher classes.

Reporting by class

ClassReportFrequency
Class IPost-market surveillance report (Article 85)Updated when necessary, made available on request
Class IIaPSUR (Article 86)When necessary and at least every two years
Class IIbPSURAt least annually
Class III and implantable devicesPSUR, submitted to the Notified Body through the electronic systemAt least annually

What the PSUR contains

PMCF

Post-market clinical follow-up (Annex XIV, Part B) proactively collects clinical data on the device in use, to confirm safety and performance, identify emerging risks and verify the benefit-risk ratio. It is planned in a PMCF plan and summarised in a PMCF evaluation report that updates the clinical evaluation. Where PMCF is not considered necessary, the justification must be documented.

Links with vigilance

PMS data feeds vigilance and trend reporting: serious incidents and field safety corrective actions are reported under Article 87, and statistically significant increases in non-serious incidents under Article 88.

Frequently asked questions

How often must a PSUR be updated?

At least annually for Class IIb and Class III devices, and when necessary and at least every two years for Class IIa devices.

Do Class I devices need a PSUR?

No. Class I manufacturers prepare a post-market surveillance report under Article 85, updated when necessary.

Is PMCF mandatory?

PMCF is part of the post-market surveillance plan. If a manufacturer considers it not necessary, it must justify that in the plan.

Related

Technical documentation

Where PMS documents sit.

Clinical evaluation

CER and PMCF strategy.

Vigilance deadlines

On getEAR.eu.

Note: This guide provides general information about Regulation (EU) 2017/745 (MDR) and Regulation (EU) 2017/746 (IVDR), not legal advice. Check the consolidated text on EUR-Lex and the relevant MDCG guidance for your device. Last reviewed 30 September 2026.