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FDA Artificial Intelligence/Machine Learning (AI/ML)-Based Software as a Medical Device (SaMD) Action Plan

Verified Checked against its sources on 3 sources quoted

Agency
Food and Drug Administration (CDRH)
Instrument
Action plan (non-binding)
Status
Plan published January 2021; still listed as an additional resource on FDA's AI-enabled medical devices page (content current as of September 22, 2026)
Issued
January 2021
Effective
January 2021
Applies to
Manufacturers of AI/ML-based software as a medical device
Sectors
Healthcare: medical devices
Applicability
AI/ML-based SaMD
Penalties and enforcement
None (a plan); devices remain subject to FD&C Act requirements
Enforcing authority
FDA

Summary

FDA's Center for Devices and Radiological Health published a five-part action plan in January 2021, responding to feedback on its 2019 discussion paper on modifications to AI/ML-based software as a medical device. It is a work plan, not a rule or guidance. Later FDA outputs on the same themes, now listed on FDA's AI-enabled medical devices page, include the Good Machine Learning Practice guiding principles (October 2021, with Health Canada and the UK MHRA), guiding principles on PCCPs and on transparency for ML-enabled devices, the final PCCP guidance for AI-enabled device software functions (December 2024, revised August 2025) and the draft lifecycle guidance (January 2025). FDA reports more than 1,600 AI-enabled devices authorized as of September 2026.

Key dates

  1. January 2021Takes effect
  2. January 2021Issued
  3. October 16, 2026Checked against sources
  4. October 21, 2026Checked against sources

Developments are added when the record is reviewed. Next review: October 16, 2027.

Evidence

Each passage is quoted from its source. The quoted passages are re-checked against the live pages every month.

  1. Additional Resources Artificial Intelligence Program: Research on AI/ML-Based Medical Devices Artificial Intelligence and Machine Learning Software as a Medical Device Action Plan

    Supports: Plan still listed; URL redirects to /artificial-intelligence-enabled-medical-devices

    The FDA has authorized over 1,600 AI-enabled medical devices for marketing in the United States as of September 2026.

    Supports: Current context

    Guiding Principles Good Machine Learning Practice for Medical Device Development Predetermined Change Control Plans for Machine Learning-Enabled Medical Devices Transparency for Machine Learning-Enabled Medical Devices

    Supports: Related guiding principles

    Artificial Intelligence-Enabled Medical Devices U.S. Food and Drug Administration Primary source

  2. Software as a Medical Device (SaMD) Action Plan January 2021

    Supports: Title and date

    we will briefly describe a five-part Action Plan to advance this work.

    Supports: Five-part plan

    AI/ML-Based SaMD Action Plan U.S. Food and Drug Administration, CDRH Primary source

  3. The final document from IMDRF builds on the guiding principles released in October 2021 by the U.S. Food and Drug Administration, Health Canada, and the United Kingdom's Medicines and Healthcare products Regulatory Agency.

    Supports: GMLP date

    Good Machine Learning Practice for Medical Device Development: Guiding Principles U.S. Food and Drug Administration Primary source

Suggested citation. Eminence Scan, “FDA Artificial Intelligence/Machine Learning (AI/ML)-Based Software as a Medical Device (SaMD) Action Plan”, Eminence Growth Solutions, last verified October 16, 2026, https://eminencegrowthsolutions.com/tools/eminence-scan/record/fed-048/.

Using our research: you may read and quote Eminence Scan with credit to “Eminence Scan, Eminence Growth Solutions” and a link; all other rights reserved. Terms: Using our research.

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