In this edition

3 signals for your next decision

  1. RecentProposed FDA guidance agenda

    FDA prioritizes medical AI lifecycle and change-control guidance

    What changed
    FDA’s FY2027 agenda prioritizes final guidance on AI device software lifecycle management, predetermined change control plans and quality-system information for certain submissions.
    Why it matters
    Japanese medical-AI teams should anticipate evolving documentation and update-management expectations when planning U.S. development milestones.
    Consider next
    Compare the agenda with your submission calendar, monitor publication and consider comments by November 30.
    Sources & context3 sources
    Relevant to
    Regulated medical AI, adaptive software and teams preparing U.S. device submissions
    Limits to keep in mind
    An agenda to finalize guidance is not issued final guidance. Priorities and publication timing may change.
    Source date: Oct 1, 2026
  2. RecentFinal order: requested partial exemption denied

    Radiology AI: the requested broad 510(k) exemption was denied

    What changed
    A September final order confirmed FDA’s denial of a proposed partial 510(k) exemption for specified radiology detection, diagnosis, triage and notification software. The denial was issued April 1.
    Why it matters
    An earlier clearance does not create the broad exemption sought for subsequent products.
    Consider next
    Retain the applicable regulatory pathway and submission budget; assess each intended use and modification before U.S. commercialization.
    Sources & context1 source
    Relevant to
    Radiology AI under 21 CFR 892.2060, 892.2070, 892.2080 or 892.2090
    Limits to keep in mind
    The order did not grant an exemption. Requirements remain product- and modification-specific; the September order became effective September 17, 2026.
    Source date: Sep 17, 2026Event / deadline: Sep 17, 2026
  3. OngoingRecurring annual registration window is open

    Foreign manufacturers: verify FDA registration by December 31

    What changed
    The annual October 1–December 31 establishment-registration verification window is open. Foreign manufacturers subject to registration must designate a U.S. Agent.
    Why it matters
    Japanese manufacturers need an accountable owner coordinating the Japanese entity, U.S. Agent, device listings and required fee payment.
    Consider next
    Confirm your establishment’s obligations, reconcile device and contact information, and complete verification before December 31.
    Sources & context1 source
    Relevant to
    Foreign device manufacturers and specification developers subject to establishment registration
    Limits to keep in mind
    This is an existing annual obligation, not a new 2026 policy. Registration does not confer marketing authorization; assess exemptions and establishment roles individually.
    Source date: Feb 2, 2026Event / deadline: 2026-10-01 to 2026-12-31