IVDR Transition Deadline extended up to 2027 – reality bites

The European Commission pushes forward with the non-extension of the IVDR deadline

Despite repeated statements that the IVDR deadline of 26 May 2022 would not be extended, that is precisely what the European Commission has just done.

Whilst just a proposal at the moment, ratification by the European Parliament and Council is just a formality and formal adoption by publication in the Official Journal of the European Union will follow.

The problem with the current IVDR deadline is two-fold:

1) Six notified bodies have been designated (approved) to date with just 11 applications pending and

2) About 80% of IVDRs previously designated as Class A (self-declaration) have been reclassified as Class B (notified) [where all the bodies that justify this reclassification is a mystery especially when the FDA presently have the opposite policy].


This is not a Blanket Extension


What’s proposed is not a blanket extension to May 2027 but is a more graded approach. This is summarised in the table below.


Summary of IVDR Transition Deadlines

IVDR Class


CE Mark by

Class D

May 2025

Notified Body

Class C

May 2026

Notified Body

Class B

May 2027

Notified Body

Class A sterile

May 2027

Notified Body

Class A non-sterile

May 2022


All New IVDRs *

May 2022

Notified Body

(*) (*) .(*) other than Class A non-sterile, which continue as self-declaration.


Class B device manufacturers, most of whom will not have had need of a Notified Body previously, should not delay in seeking one out. They are not going to be easy to find despite the 5-year postponement.


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The IVDR Deadline has not been postponed


Note carefully that the postponement refers solely to the production of Certificates of Conformity for CE Marks. The IVD Regulations themselves will otherwise apply in full from 26th May 2022.

Requirements for Vigilance and Market Surveillance may prove challenging for those manufacturers currently in the self-declared space.

The EUDAMED Database has to be populated also


And then there’s the introduction of the EUDAMED database of three modules:

1. Actors registration,

2. UDI/Devices registration and

3. Notified Bodies and Certificates.

The deadline for the other 3 modules remains 26th June 2022 (same as for IVDR). These latter three are:

4. Clinical investigations and performance studies,

5. Vigilance and post-market surveillance and

6. Market Surveillance.

It is anticipated that manufacturers without a dedicated Regulatory Affairs resource will struggle and for some, it is already too late regarding clinical investigations and performance studies.


Shades of Sisyphus


The postponement of the IVDR deadline offers some respite, but there’s still a regulatory mountain to climb for IVDR as well as MDR manufacturers. We wish you luck.

For detailed information


The full text of the Commission’s proposal can be found in this European Commission document.

Up to date information on the EUDAMED Database can be found at the European Commission's EUDAMED overview post.



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Written by Dr John FitzGerald

Director & Founder of deGRANDSON Global. Spent 15 years in the manufacturing industry and 25 years training, consulting & auditing management systems
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