
FDA published draft guidance on Software as a Medical Device (SaMD) Clinical Evaluation on March 19, 2026.
Key change: real-world evidence now acceptable for post-market surveillance in lieu of RCTs for certain Class II AI/ML-enabled devices.
I read the 47-page guidance twice. The implications are larger than the headlines suggest.
Continuous learning AI systems can now demonstrate safety/efficacy through deployed performance data instead of freezing the algorithm for a 2-year RCT.
Public comment period: 90 days. If you are building adaptive AI diagnostics, this is the regulatory precedent that changes your product roadmap.

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