Checklist

FDA QMSR transition checklist

Confirm the QMSR transition is complete — task by task, with owners and evidence. QMSR has been in effect since 2 February 2026.

The QMSR took effect on February 2, 2026 — ISO 13485:2016 incorporated by reference, QSIT retired, and records that were previously off-limits now reviewable in inspections. This checklist turns the transition into 19 tracked tasks across six phases, each with an owner, status, and evidence reference. Companion to the QMSR transition hub.

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FDA QMSR transition checklist — the Excel workbook you download, showing its columns and structure

What the checklist covers

Nineteen tasks across six phases: gap assessment (mapping legacy procedures to ISO 13485 clauses plus the FDA additions at 820.35 and 820.45), change-controlled document updates, management review as a producible record per ISO 13485 §5.6, the re-pointed internal audit program, training on every revised procedure, and readiness drills — including a timed retrieval exercise, because the new inspection program selects records by risk and waits while you produce them.

Each task row has owner, status (dropdown), evidence/record-reference, and notes columns, plus an Instructions tab and a worked example. Add site-specific rows as your gap assessment surfaces them.

  • Gap assessment against ISO 13485 clauses plus 820.35 and 820.45
  • Change-controlled document updates
  • Management review as a producible record per §5.6
  • Re-pointed internal audit program and training on every revised procedure
  • Readiness drills including a timed retrieval exercise

Why run the transition as tracked, evidenced work

Most QSR-era systems need a structured gap assessment, not a rewrite — but the work that is needed leaves a trail an investigator can now follow: management review minutes, internal audit findings, and supplier audit records are all reviewable under compliance program CP 7382.850. A checklist with owners and evidence references means the transition itself becomes inspection evidence rather than an undocumented scramble.

Running the transition in a governed system

The checklist works on its own — and works better when the underlying activities run in governed workflows: the document wave under change control, the gap assessment in audit management, training evidence tied to revisions, and management review minutes as controlled, signed records.

Frequently asked questions

When did FDA QMSR take effect?

The Quality Management System Regulation became effective on 2 February 2026, replacing 21 CFR Part 820's QSIT-era framework and incorporating ISO 13485:2016 by reference. Device firms are expected to have completed their transition.

What changes most under QMSR compared to Part 820?

The alignment to ISO 13485 clause structure, explicit incorporation of risk management, and inspectability of records that were previously exempt — notably management review and internal audit records, which FDA can now review during inspections.

How do I use this transition checklist?

Nineteen tracked tasks walk gap assessment against the ISO 13485 clauses, documentation updates, training, and verification, each with owner, status and evidence-reference columns — the structure doubles as your objective evidence that the transition itself was controlled.

Run the QMSR transition inside a governed quality system

In Complere the document wave runs under change control, the gap assessment lives in audit management, training evidence ties to revisions, and management review minutes are controlled, signed records — so the transition itself becomes inspection evidence.