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FDA Final Guidance on Computer Software Assurance Released

On 24th Sept  2025, the FDA published its final guidance on Computer Software Assurance (CSA) for production and quality system software.

What’s new?
CSA formalizes a risk-based approach to ensure software used in production and quality systems is fit for its intended use and remains in a validated state throughout its lifecycle:

  • Risk drives validation: Identify intended use by feature/function. High-risk areas that could impact patient safety or product quality require more rigorous assurance.

  • Digital over paper: System logs, audit trails, and automated outputs are preferred to paper-heavy documentation.

  • Leverage vendor evidence: Certifications, SDLC documentation, cybersecurity practices, and service agreements can support your assurance activities.

  • Lifecycle focus: For SaaS auto-updates, apply targeted regression testing instead of full revalidation.

CSA is not “less validation”  – it’s smarter, risk-based validation.

Full guidance here: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/computer-software-assurance-production-and-quality-system-software-0