1

Determined device risk classification (Class I, Is, Im, IIa, IIb, III, AIMD, or IVD category)
2

Confirmed whether a UK Approved Body is required for your device class
3

Compiled technical documentation (device description, design information, risk management file, clinical evaluation, labels, instructions for use)
4

Completed conformity assessment (self-declaration for Class I or UK Approved Body assessment for higher classes)
5

Drawn up UK Declaration of Conformity (or EU Declaration of Conformity for CE-marked devices)
6

Affixed UKCA mark (or CE mark during transitional period) with UK Approved Body number if applicable
7

Registered as manufacturer (or UK Responsible Person) with MHRA via DORS
8

Registered each device with MHRA via DORS before placing on market
9

Appointed UK Responsible Person (if you are a non-UK manufacturer)
10

Established quality management system (ISO 13485 for Class Is, Im, IIa, IIb, III)
11

Gathered sufficient clinical evidence demonstrating safety and performance
12

Established post-market surveillance system proportionate to device class
13

Registered for the MORE portal for vigilance reporting
14

Set up process to meet vigilance reporting timelines (2/10/15 calendar days)
15

Ensured labelling is in English and includes all required information
16

Set up process to update MHRA registration within 10 working days of changes
17

Planned for UK Approved Body certificate renewal before expiry
18

Retained technical documentation (minimum 10 years, 15 years for implantables)

Medical device classification system

Risk-based classification system for medical devices determining regulatory pathway.

Class I (lowest risk): Non-invasive devices with minimal risk — self-certification by manufacturer (e.g., bandages, wheelchairs, stethoscopes)
Class Is (sterile, low risk): Sterile low-risk devices — self-certification plus UK Approved Body assessment for sterility aspects (e.g., sterile bandages, sterile surgical gloves)
Class Im (measuring, low risk): Low-risk devices with measuring function — self-certification plus UK Approved Body for metrological aspects (e.g., non-invasive thermometers, graduated syringes)
Class IIa (low-medium risk): Short-term invasive devices and diagnostic equipment — UK Approved Body assessment required (e.g., hearing aids, dental crowns, blood pressure monitors)
Class IIb (medium-high risk): Long-term invasive and surgically invasive devices — UK Approved Body full assessment required (e.g., ventilators, blood bags, condoms)
Class III (highest risk): Devices contacting heart or CNS, containing medicinal substances, or made from animal tissue — UK Approved Body full design examination and QMS assessment (e.g., heart valves, hip implants, coronary stents, pacemakers)
Active implantable medical devices (AIMD): Devices totally or partially introduced into the human body and intended to remain — UK Approved Body full assessment required (e.g., cardiac pacemakers, cochlear implants, neurostimulators)
Classification basis: Classification determined by intended purpose, invasiveness, duration of body contact, and whether device is active — rules in Annex IX of retained Directive 93/42/EEC

Medical device classification guidance

Medical Device Registration Fees (UKCA Marking)

MHRA fees for medical device manufacturer and device registration

Statutory registration fee: £300 per Level 2 GMDN Category (or Level 1 where no Level 2 exists), applicable since 1 April 2026
Device registration requirement: All devices placed on UK market must be registered
Registration update deadline: 10 working days for any changes
Technical file retention: Minimum 10 years after last device placed on market
UK Responsible Person (UKRP): Mandatory for non-UK manufacturers
Clinical investigation fee (Class I and IIa): £15,309
Clinical investigation fee (Class IIb implantable/long-term invasive): £24,617
Clinical investigation fee (Class III and active implantable): £32,016
Clinical investigation amendment fee: £0 (no fee for amendments from 16 July 2025)
Average clinical investigation approval time: 51 calendar days

Medical device vigilance reporting timelines

Statutory timelines for reporting serious medical device incidents to MHRA, effective 16 June 2025.

Effective date: 16 June 2025
Serious public health threat: 2 calendar days from when manufacturer becomes aware
Death or unanticipated serious deterioration in health: 10 calendar days from when manufacturer becomes aware
All other reportable serious incidents (including anticipated serious deterioration): 15 calendar days from when manufacturer becomes aware
Previous reporting deadline (replaced): 30 calendar days
Reporting portal: MHRA MORE (Medical Online Reporting Environment)
Who must report: UK Responsible Person, manufacturer, or authorised representative
Reportable serious incident definition: Death of a patient, user, or other person; serious deterioration in the state of health; or a serious public health threat
Trend reporting: Required when statistical patterns of incidents are identified
Field Safety Corrective Action (FSCA): Required when investigation identifies risk to devices already on the market (e.g. recall, modification, additional warnings)
Geographic scope: Great Britain (England, Scotland, Wales)

MHRA Vigilance Reporting Requirements

MHRA Penalties and Enforcement Powers

Penalties for non-compliance with medicines and medical devices regulations, distinguishing between medicines offences and device offences.

MHRA uses a graduated enforcement approach from informal advice through warning letters and statutory notices to criminal prosecution. The Medicines and Medical Devices Act 2021 introduced modern enforcement tools including civil monetary penalties as an alternative to prosecution.

MEDICAL DEVICES: Breach of UK MDR or enforcement notice: Up to 6 months imprisonment and/or unlimited fine
MEDICAL DEVICES: Civil monetary penalty (alternative to prosecution): Variable amount set by MHRA under MMD Act 2021, Section 31
MEDICAL DEVICES: Supplying falsified medical device: Up to 2 years imprisonment and/or unlimited fine (Consumer Protection Act 1987)
MEDICINES: Manufacturing without licence: Unlimited fine + up to 2 years imprisonment
MEDICINES: Wholesale distribution without licence: Unlimited fine + up to 2 years imprisonment
MEDICINES: Falsified medicines supply: Unlimited fine + up to 10 years imprisonment
BOTH: Obstruction of MHRA inspector: Criminal offence — unlimited fine (Consumer Rights Act 2015, Schedule 5)
Enforcement escalation: Informal advice → warning letters → compliance notices (s.24) → suspension notices (s.25) → safety notices (s.26) → recall notices (s.28) → civil sanctions (s.31) → criminal prosecution

Medical device compliance checklist

MHRA licensing for medicines and medical devices

Report a medical device safety incident to MHRA

MHRA authorisation for medicines and medical devices

Post-market surveillance for medical devices

Software and AI as medical devices (SaMD/AIaMD)

Determined device risk classification (Class I, Is, Im, IIa, IIb, III, AIMD, or IVD category)

Confirmed whether a UK Approved Body is required for your device class

Compiled technical documentation (device description, design information, risk management file, clinical evaluation, labels, instructions for use)

Completed conformity assessment (self-declaration for Class I or UK Approved Body assessment for higher classes)

Drawn up UK Declaration of Conformity (or EU Declaration of Conformity for CE-marked devices)

Affixed UKCA mark (or CE mark during transitional period) with UK Approved Body number if applicable

Registered as manufacturer (or UK Responsible Person) with MHRA via DORS

Registered each device with MHRA via DORS before placing on market

Appointed UK Responsible Person (if you are a non-UK manufacturer)

Established quality management system (ISO 13485 for Class Is, Im, IIa, IIb, III)

Gathered sufficient clinical evidence demonstrating safety and performance

Established post-market surveillance system proportionate to device class

Registered for the MORE portal for vigilance reporting

Set up process to meet vigilance reporting timelines (2/10/15 calendar days)

Ensured labelling is in English and includes all required information

Set up process to update MHRA registration within 10 working days of changes

Planned for UK Approved Body certificate renewal before expiry

Retained technical documentation (minimum 10 years, 15 years for implantables)

Compliance resources

Related guides in General Compliance