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UK's Software and AI as a Medical Device Change Programme

In today's technologically driven world, software, including Artificial Intelligence (AI), is revolutionizing various industries, including health and social care. In the United Kingdom, these digital products are increasingly being regulated as medical devices to ensure patient safety and public protection. Last year, the Medicines and Healthcare products Regulatory Agency (MHRA) unveiled the Software and AI as a Medical Device Change Programme, a comprehensive initiative aimed at establishing clear regulatory requirements for software and AI while fostering responsible innovation within the medical device industry. The primary goal of the Change Programme is to create a regulatory framework that not only guarantees a high degree of patient and public protection but also positions the UK as a global hub for responsible innovation in medical device software.

To achieve this ambitious vision, the Programme focuses on three broad objectives:

  • Ensuring Device Safety and Functionality: The first objective is to establish rigorous requirements that provide assurance of the safety and intended functionality of software and AI as medical devices. By setting stringent standards, the Programme aims to safeguard patients and the public from potential risks and malfunctions associated with these technologies.

  • Clear Requirements for Manufacturers: The second objective revolves around providing manufacturers with clear and unambiguous guidelines. Through clarificatory guidance and streamlined processes, the Change Programme intends to facilitate compliance for software developers. The designation of standards will also play a crucial role in demonstrating manufacturers' adherence to the prescribed regulations.

  • Removing Market Friction: To promote the widespread adoption of digital health solutions, the Programme aims to collaborate with key partners like the National Institute for Health and Care Excellence (NICE) and NHS England. This partnership will facilitate alignment, reduce duplication, and create a unified digital health ecosystem within the UK. Furthermore, on an international level, the Programme will collaborate with regulators worldwide, including the International Medical Device Regulators Forum (IMDRF), to foster global convergence and consensus on software and AI products.

The Structure of the Change Programme:

The Software and AI as a Medical Device Change Programme comprises eleven work packages, divided into two workstreams. The first workstream includes eight packages focused on reforming the software as a medical device (SaMD) lifecycle. The second workstream consists of three packages specifically addressing the unique challenges posed by AI as a medical device (AIaMD) compared to traditionally programmed software.

Collaborative Approach:

Developed with input from various stakeholders, the Change Programme reflects a collaborative effort across government and the National Health Service (NHS). Partnerships with devolved administrations, trade associations, academia, and industry players have shaped the Programme's strategies and objectives. Going forward, the Multi Agency Advisory Service, comprising NICE, Care Quality Commission (CQC), and Health Research Authority (HRA), will continue to contribute to the ongoing development of this critical initiative.


The Software and AI as a Medical Device Change Programme stands as a testament to the UK's commitment to responsible innovation in the healthcare sector. By establishing a robust regulatory framework, ensuring device safety, and fostering global collaboration, the Programme paves the way for the widespread adoption of digital health solutions while prioritizing patient protection and public safety. As the world embraces the potential of AI and software in healthcare, the UK positions itself as a trailblazer in the responsible application of these technologies on a global scale.

AF Pharma, as a leading UKRP (UK Responsible Person), can play a pivotal role in supporting the Software and AI as a Medical Device Change Programme. With extensive expertise in regulatory affairs and medical device compliance, AF Pharma is well-equipped to assist software and AI manufacturers in navigating the complex landscape of regulations and guidelines. Our team of seasoned professionals can help streamline the process of obtaining regulatory approvals by providing comprehensive guidance on meeting safety and functionality requirements. Moreover, AF Pharma's collaboration with key partners, such as NICE and NHS England, ensures a seamless integration of digital health products within the UK market. Additionally, our global network allows us to engage with international regulators through the IMDRF, fostering convergence and harmonization of standards. As a dedicated advocate of responsible innovation, AF Pharma is committed to empowering companies to deliver cutting-edge medical device software solutions while upholding the highest standards of patient and public safety.

Software and IA - UK
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