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ISO 14155:2020 · EU MDR Articles 62–82 · India MDR 2017 · FDA IDE

Clinical Investigation for Medical Devices under ISO 14155, EU MDR and India MDR 2017

REGHELPS plans and runs medical device clinical investigations end to end: clinical strategy, protocol and investigator’s brochure, ethics and regulatory approvals, site management, monitoring, data management, biostatistics and the final clinical investigation report for CE marking, FDA or CDSCO.

10 daysEU validation of an application
45 daystypical EU authorisation decision
2 / 7 daysserious adverse event reporting
1 yearto submit the investigation report
The basics

What is a clinical investigation for medical devices?

A clinical investigation is a systematic study in human subjects to assess the safety, clinical performance and clinical benefit of a medical device. It is the device equivalent of a clinical trial, and the strongest source of clinical evidence for your CE marking, FDA submission or CDSCO licence.

Clinical investigations are most often needed for implantable and Class III devices, novel technologies and new intended purposes where there is no equivalent device with enough clinical data. They must follow ISO 14155:2020 good clinical practice and the rules of each country where the study runs.

Clinical investigation vs clinical evaluation: the investigation generates new clinical data; the clinical evaluation report (CER) assesses all clinical data, including your investigation results, literature and PMCF.
GCP
ISO 14155 compliantProtocols, monitoring and records built to good clinical practice.
EU
Multi-country readyEU Member States, India, USA and other markets.
◎
Built for your submissionEndpoints chosen to answer what your Notified Body, FDA or CDSCO will ask.
↻
Feeds your CER and PMCFResults integrated into clinical evaluation and post-market plans.
Decision flow

Do you need a clinical investigation for your device?

The decision flow we use with manufacturers planning CE marking under EU MDR. Final decisions depend on your device, claims and Notified Body.

Question 1Is the device implantable or Class III?
YesA clinical investigation is required unless an Article 61(4)–(6) exemption applies. Go to question 2.
NoGo to question 3.
Question 2Can you claim equivalence with full access to the equivalent device’s technical and clinical data, or is it a well-established technology?
YesAn exemption may apply. Document the justification in the CER.
NoPlan a pre-market clinical investigation under ISO 14155.
Question 3Do existing clinical data, literature and equivalence show safety, performance and benefit for every claim?
YesNo investigation needed now. Confirm the evidence with PMCF.
NoPlan a targeted clinical investigation to close the gaps.
Study types

Types of medical device clinical investigations

Device studies follow the device lifecycle. We help you choose the smallest study that will still convince your regulator.

Early feasibilityFirst-in-human studies in a small group to check initial safety and device function.
Traditional feasibilityConfirm design, procedure and endpoints before a larger study.
Pivotal studyConfirmatory study that provides the main evidence for approval.
Market approvalCE marking, FDA clearance or approval, CDSCO licence.
Post-market studyPMCF investigation or registry to confirm long-term safety and performance.
Study typeTypical designTypical sizeTypical duration
Early feasibility / first-in-humanSingle-arm, prospective10–30 subjects6–12 months
Pivotal studyRandomised controlled or single-arm with performance goalsDetermined by sample size calculation18–36 months
PMCF investigationProspective, within intended purpose (Article 74)Driven by the clinical question12–36 months
Other investigationsArticle 82, under national rulesVariesVaries
By market

Clinical investigation requirements in the EU, USA and India

The same study can support several markets if it is planned for all of them from the start.

TopicEuropean UnionUnited StatesIndia
Legal basisEU MDR Articles 62–82, Annex XV21 CFR 812 (IDE), 21 CFR 50 and 56Medical Devices Rules 2017, Chapter VII
RegulatorNational competent authorities of each Member StateFDA (CDRH)CDSCO, Central Licensing Authority
Ethics reviewEthics committee in each Member StateInstitutional Review Board (IRB)Ethics committee registered with CDSCO
ApplicationAnnex XV Chapter II documents to each Member StateIDE application for significant-risk devicesForm MD-22; permission on Form MD-23
GCP standardISO 14155:202021 CFR 812, with ISO 14155 accepted for many studiesISO 14155 and Indian GCP
RegistrationEUDAMED when fully functional; national systems nowClinicalTrials.gov where applicableClinical Trials Registry of India (CTRI)
Approval flow

EU MDR clinical investigation approval: step by step

How an application moves through a Member State under MDR Article 70.

Submit applicationSponsor submits the Annex XV documents to each Member State concerned.
ValidationThe Member State checks completeness within 10 days.
Route A: Class I or non-invasive IIa/IIbMay start right after validation, unless national law says otherwise.
Route B: all other devicesAuthorisation decision normally within 45 days of validation (+20 days if experts consulted).
Start and reportRun the study, report SAEs and submit the final report within 1 year.
✓Ethics committee approval is always required alongside regulatory validation or authorisation.
Study documents

Key documents we prepare for your clinical investigation

01
Clinical investigation plan (CIP)Objectives, design, endpoints, sample size and statistical analysis.
02
Investigator’s brochure (IB)Device description, pre-clinical data and known risks for investigators.
03
Informed consentPatient information and consent forms in local languages.
04
Case report forms (eCRF)Data capture designed around your endpoints.
05
Regulatory and ethics dossiersMember State, FDA IDE or CDSCO MD-22 submissions.
06
Clinical investigation reportFinal report and lay summary for your CER and submissions.
How we run studies

From clinical strategy to final report

REGHELPS runs your clinical investigation as a full-service CRO, with one team accountable from first plan to final report.

  1. 1

    Clinical strategy

    Planning

    We define what evidence your regulators need and design the smallest study that delivers it.

  2. 2

    Protocol and study documents

    CIP · IB · ICF

    We write the CIP, investigator’s brochure, consent forms and CRFs to ISO 14155.

  3. 3

    Approvals

    Ethics · regulators

    We prepare and manage ethics, Member State, FDA IDE or CDSCO submissions.

  4. 4

    Site feasibility and selection

    Sites

    We find sites with the right patients and experience, and negotiate agreements.

  5. 5

    Site initiation and training

    Start-up

    We train investigators and staff on the protocol, device and GCP.

  6. 6

    Recruitment and consent

    Enrolment

    We support patient recruitment and check consent is obtained properly.

  7. 7

    Monitoring

    Risk-based

    Our monitors verify data and protect patient safety through on-site and remote visits.

  8. 8

    Data management and safety reporting

    eCRF · SAE

    We manage data quality and report serious adverse events and device deficiencies on time.

  9. 9

    Biostatistics and final report

    CIR

    Our biostatisticians analyse the data and we write the clinical investigation report.

  10. 10

    CER and submission support

    Close the loop

    We integrate the results into your CER and support Notified Body, FDA or CDSCO questions.

Avoid delays

Common clinical investigation pitfalls

01
Endpoints that miss the claimData that does not support the indications you want on the label.
02
Unjustified sample sizeNo statistical basis, leading to regulator questions.
03
Slow recruitmentSites chosen without checking patient numbers.
04
Incomplete applicationsMissing Annex XV documents delay validation.
05
Late safety reportingSAEs reported outside the required timelines.
06
Poor data qualityWeak monitoring and source data verification.
Our services

Our clinical investigation services

Clinical strategy and study designEvidence plans and study designs regulators accept.
Protocol and document writingCIP, IB, ICF and CRFs to ISO 14155.
Regulatory and ethics submissionsEU Member States, FDA IDE and CDSCO.
Site management and monitoringFeasibility, contracts, initiation and risk-based monitoring.
Data management and biostatisticseCRF build, data cleaning and statistical analysis.
Clinical investigation reportFinal report, lay summary and CER integration.
FAQ

Clinical investigation FAQs

When is a clinical investigation required under EU MDR?

Under MDR Article 61(4), clinical investigations are required for implantable and Class III devices, unless an exemption applies, such as demonstrated equivalence with full access to the equivalent device’s data, or certain well-established technologies. For other classes, an investigation is needed whenever existing clinical data is not enough to show safety, performance and clinical benefit.

How long does EU approval for a clinical investigation take?

After submission, the Member State validates the application within 10 days. Class I and non-invasive Class IIa and IIb devices may start right after validation unless national law says otherwise. Other devices need authorisation, which is normally decided within 45 days of validation, extendable by 20 days for expert consultation.

What documents are needed to start a clinical investigation?

The core set is the clinical investigation plan (CIP), investigator’s brochure (IB), informed consent form, case report forms, investigator CVs and agreements, insurance cover, ethics committee opinion, regulatory authorisation and, in the EU, the documents listed in MDR Annex XV Chapter II.

Do I need a clinical investigation to sell my device in India?

Under the Medical Devices Rules 2017, an investigational medical device needs a clinical investigation before it can be licensed, unless the Central Licensing Authority waives it, for example when the device is already approved in certain reference countries. Permission is requested on Form MD-22 and granted on Form MD-23, with ethics committee approval and CTRI registration.

What is ISO 14155?

ISO 14155:2020 is the international good clinical practice standard for clinical investigations of medical devices in humans. It covers study design, ethics, sponsor and investigator responsibilities, monitoring, safety reporting and documentation, and is harmonised under EU MDR.

What is the difference between clinical investigation and clinical evaluation?

A clinical investigation is a study that generates new clinical data in human subjects. Clinical evaluation is the ongoing assessment of all available clinical data, including investigation results, literature and PMCF, documented in the clinical evaluation report (CER).

How are serious adverse events reported in an EU clinical investigation?

Under MDR Article 80 and MDCG 2020-10/1, serious adverse events and device deficiencies that could have led to one must be reported to the authorities without delay: no later than 2 calendar days if there is an imminent risk of death or serious injury, and within 7 calendar days for other reportable events.

When must the clinical investigation report be submitted?

Under MDR Article 77(5), the sponsor submits the clinical investigation report within one year of the end of the investigation, or within three months if it is terminated early or halted, together with a summary that is easy for the intended user to understand.

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