Neuromodulation · Implantable neurostimulation · Regulation (EU) 2017/745

European neuromodulation CRO for implantable neurostimulation clinical programmes.

Eclevar supports first-in-human, pivotal and PMCF programmes for implantable neurostimulation systems across Europe, integrating clinical strategy, specialist-site feasibility, monitoring, biometrics, medical writing and regulatory evidence planning.

Neurostimulation clinical evidence architecture Five connected domains (patient, implantable system, clinician and workflow, clinical data, and regulatory evidence) sitting above a band of cross-cutting data elements comprising software version, stimulation settings, programming changes, device deficiencies, and revision and explant data. PATIENT Indication · Patient selection Responder definition IMPLANTABLE SYSTEM Pulse generator · Lead · Electrode array Device configuration CLINICIAN AND WORKFLOW Implantation · Programming · Training Revision and explant pathway CLINICAL DATA Symptoms · Function Quality of life · Safety REGULATORY EVIDENCE First-in-human · Pivotal investigation PMCF · CER integration CROSS-CUTTING DATA ELEMENTS Software version · Stimulation settings Programming changes · Device deficiencies Revision and explant data
Evidence must connect the implanted system, the programmed therapy, the clinical workflow and the patient outcome.
Individual experience

Class III evidence strategy

Clinical evidence strategy informed by first-hand Notified Body review experience.

Eclevar delivery

European clinical delivery

Implanting-centre qualification, activation and monitoring under ISO 14155:2026.

Eclevar delivery

Structured stimulation-data capture

Settings, programming history and device events captured as queryable data, not free text.

Eclevar delivery

PMCF and CER integration

Long-term follow-up designed to feed the clinical evaluation report it has to support.

Neurostimulation systems covered

Six system families, each with a different evidence problem.

A spinal cord stimulation pivotal study and a responsive neurostimulation feasibility study share almost nothing beyond the regulation. Select a system to see what changes, and what Eclevar can take on today.

Epidural leadDorsal root ganglionPulse generator
Posterior view · lumbar placement

Labelled in the illustration: Epidural lead · Dorsal root ganglion · Pulse generator

Relevant team experience

Spinal cord stimulation (SCS) and dorsal root ganglion stimulation (DRG)

Chronic neuropathic pain · failed back surgery syndrome · complex regional pain syndrome

Trial-to-implant conversion, patient-reported outcome burden and long lead survival horizons make these the most operationally demanding neuromodulation studies to run in Europe. Eclevar's relevant team experience here is in Class III implantable device methodology and spinal surgical pathway design, not in stimulation programming.

What the study has to resolve

  • Trial stimulation period and conversion criteria
  • Responder definition justified for the indication
  • Lead migration, revision and explant capture
  • Concomitant analgesic use as a confounder

What Eclevar takes on

  • Clinical investigation plan and statistical analysis plan
  • Implanting-centre feasibility and activation
  • Electronic data capture for stimulation settings
  • Clinical investigation report and CER integration
Spinal cord stimulation clinical trials · child page in preparation

Programme journey

Where your neurostimulation system is now decides what evidence comes next.

  1. STAGE 01

    Evidence gap and European feasibility

    Establish what the existing clinical data supports, what it does not, and whether European implanting centres can recruit the population you need.

    Principal deliverableEvidence gap analysis and specialist-centre feasibility report

  2. STAGE 02

    First-in-human and early feasibility

    A small, tightly monitored investigation to characterise implantation, stimulation tolerability and early device performance.

    Principal deliverableClinical investigation plan and competent authority submission pack

  3. STAGE 03

    Pivotal clinical investigation

    The study that carries the benefit-risk argument, with an endpoint and responder definition justified for your specific indication.

    Principal deliverableMonitored multicentre investigation and clinical investigation report

  4. STAGE 04

    PMCF and long-term follow-up

    Device longevity, lead integrity, revision and explant events tracked over the years in which they actually occur.

    Principal deliverablePMCF plan (MDCG 2020-7) and PMCF evaluation report (MDCG 2020-8)

  5. STAGE 05

    CER and regulatory integration

    Every dataset consolidated into a clinical evaluation report structured for the questions a Notified Body is likely to ask.

    Principal deliverableClinical evaluation report and updated clinical evidence dossier

Therapeutic differentiator

The five variables that determine whether a neurostimulation study is interpretable.

Get any one of these wrong and the dataset may still be complete, monitored and on time, and still fail to answer the question it was built to answer. Select a variable to see what is at stake and how Eclevar handles it.

INTERPRETABLE STUDY all five must hold 01 Indication and endpoint 02 Patient selection and responder definition 03 Stimulation settings and programming history 04 Implantation, revision and explant pathway 05 Long-term benefit and system performance A weakness in any one variable limits what the whole dataset can support.
01Indication and endpoint

An endpoint that is defensible for chronic neuropathic pain may be inappropriate for a movement disorder or for drug-resistant epilepsy. The instrument, the timepoint and the clinically meaningful difference all need to be argued from the literature for the indication in question, not carried across from a neighbouring one.

What we doDraft the endpoint rationale against the applicable clinical literature and the relevant MDCG clinical investigation guidance, and document why alternatives were not chosen.

02Patient selection and responder definition

Responder definitions are indication-specific and contested. A threshold used widely in one chronic pain population is not automatically transferable to another indication, to a different outcome instrument, or to a different follow-up horizon. Any threshold has to be justified rather than adopted by convention.

What we doSet out the candidate definitions, their published basis and their consequences for sample size, so that the sponsor and the investigators make the choice on the record.

03Stimulation settings and programming history

A neurostimulator is not a fixed intervention. Amplitude, frequency, pulse width, contact configuration and programme changes vary between patients and over time, and if they are not captured in a structured, queryable form the study cannot describe what was actually delivered.

What we doDesign the electronic data capture so that every configuration change is time-stamped, attributable and analysable, rather than recorded in free text, and reconcile device or programmer exports against the study record.

04Implantation, revision and explant pathway

Lead migration, connector failure, infection, battery depletion and elective explant all sit on different clinical timelines. Reporting conventions differ between centres, and inconsistent coding is one of the most common reasons post-market datasets fail to answer the question asked of them.

What we doDefine the event taxonomy before first patient in, train sites against it, and reconcile it with the sponsor's vigilance and complaint-handling terminology.

05Long-term benefit and system performance

Implantable neurostimulators are expected to remain in place for years. Sustained clinical benefit, battery longevity, recharge burden and cumulative reoperation rate are separate questions, and each needs a follow-up structure that survives site turnover and patient attrition.

What we doBuild the long-term follow-up around retention from the outset, using registry structures where a prospective investigation would not be proportionate.

Endpoint selection, responder thresholds and patient-selection criteria on this page are described in general terms only. Study-specific wording is set with the sponsor and reviewed by the investigators and independent specialists appointed for the programme before it enters a protocol.

European implanting-centre delivery

Neurostimulation studies are won or lost at the implanting centre.

The pool of European centres that implant a given system is small, and the ones with the highest procedure volume are not always the ones that can carry a clinical investigation. Eclevar qualifies centres against the whole patient pathway, not against a procedure count.

PATHWAY QUALIFICATION CRITERION ASSESSED AT THIS STEP Patient pathway Implanting physician Programming team Revision and explant capability Long-term follow-up Submission-ready dataset Indication volume Implant experience Programming capability Revision and explant pathway Long-term follow-up capacity Data continuity A centre that fails any one criterion can still implant well and still cannot carry the study.
European implanting-centre qualification model. Each centre is assessed against the criterion that sits under the step it has to deliver.
  1. 01
    Patient pathwayCriterionIndication volume: procedures in the population your protocol defines
  2. 02
    Implanting physicianCriterionImplant experience with the system class under study
  3. 03
    Programming teamCriterionProgramming capability, and whose time is committed to research
  4. 04
    Revision and explant capabilityCriterionRevision and explant pathway performed on site rather than referred
  5. 05
    Long-term follow-upCriterionLong-term follow-up capacity across the device's service life
  6. 06
    Submission-ready datasetCriterionData continuity from first implant to clinical evaluation report

What we check that a procedure count will not tell you

  • Procedures in the population your protocol defines, in the twelve months before activation, rather than total implants
  • Whether the psychologist, physiotherapist or specialist nurse the protocol assumes actually exists at the centre, with capacity
  • Who programmes the device, how often, and whether that person's time is committed to research or only to routine care
  • Whether revision and explant are performed on site or referred elsewhere, which decides whether events are captured at all
  • Country-level ethics and competent authority sequencing, so activation is planned against real approval durations
  • Competing studies already open at the centre, because the most experienced neuromodulation centres are usually committed

How European coverage is delivered

Stated by delivery model rather than by a country count.

Regulatory and ethics submissionsPrepared and filed by Eclevar, not subcontracted
DACH regionLed from within the region by Eclevar clinical operations
United KingdomIn-house site delivery and lead monitoring
FranceIn-house clinical operations and project delivery
Elsewhere in EuropeQualified partners under Eclevar oversight and quality agreements
Data, biometrics and writingHeld centrally for every country in the study

Indication expansion and investigator-led evidence

Building evidence for new indications, patient populations and stimulation strategies.

Investigator-initiated and sponsor-led studies can help explore new indications, patient populations, stimulation approaches or care pathways. Eclevar structures the protocol, governance, data capture and regulatory integration around the precise scientific question and applicable legal framework.

An investigator-initiated study (IIS) is not a lighter version of a sponsor study. The legal roles differ, the sponsor's obligations differ, and the extent to which the resulting data can later support a regulatory submission depends on how the study was structured at the outset. That decision is worth making deliberately.

What we settle before the first patient

Who is the sponsor
The legal sponsor role under Regulation (EU) 2017/745, and what it obliges the investigator or the manufacturer to do.
Which framework applies
Whether the study falls under Article 62, Article 74 or Article 82, and what that means for submission, insurance and reporting.
Data ownership and reuse
Whether the manufacturer will be able to use the dataset in a clinical evaluation report, agreed in writing before enrolment.
Data capture standard
Validated electronic data capture from the start, so the dataset is submission-ready rather than reconstructed afterwards.

Programme evidence

Selected programme experience and evidence models.

Examples of Eclevar’s verified clinical-evidence contributions across neurological diagnostics and implantable neurostimulation, alongside an illustrative PMCF programme model.

Selected neurological device programme

Nihon Kohden Nihon Kohden Neurological diagnostic device programme

EU MDR clinical evidence for an electromyography and evoked-potential system

The programme required a clinically and regulatorily defensible evidence package for a neurological diagnostic system combining electromyography, nerve-conduction assessment and evoked-potential measurement, developed by Nihon Kohden.

The system records and measures nerve and muscle signals. It is a diagnostic clinical-neurophysiology platform and does not deliver therapeutic neurostimulation.

Clinical-neurophysiology workstationA cart-mounted clinical-neurophysiology workstation: acquisition monitor displaying three signal traces, control console with rotary controls, multi-channel amplifier with paired input ports, articulated arm carrying an input junction box, electrode leads to an accessory tray, storage cabinet and castors.
  • Electromyography
  • Nerve conduction
  • Evoked potentials
Electromyography and evoked-potential measuring system Clinical neurophysiology · neurological diagnostic device Proprietary illustration built on generic device-category geometry. No client product photograph, traced outline or model designation is used.

Verified delivery scope

  • Clinical evaluation strategy
  • Clinical Evaluation Report
  • Systematic literature review
  • State-of-the-art assessment
  • Clinical-data appraisal

Public scope is limited to activities verified against the contract and delivered documentation.

Regulatory purpose

The clinical evidence package was prepared to support the manufacturer’s conformity assessment under Regulation (EU) 2017/745.

No certification, approval or conformity-assessment outcome is attributed to Eclevar.

Members of the Eclevar and Nihon Kohden programme teams.
Programme teams

Eclevar and Nihon Kohden programme teams.

Image published with Nihon Kohden’s agreement.

Evidence pathway

  1. 01

    Existing clinical evidence

    Existing data is mapped against the intended purpose and the claims made.

  2. 02

    State of the art

    A systematic literature review establishes current practice and accepted diagnostic benchmarks.

  3. 03

    Clinical performance and safety

    Performance and safety are appraised against those benchmarks; residual gaps are documented.

  4. 04

    Post-market evidence planning

    Evidence still to be collected after market placement is defined, with the capture method.

  5. 05

    CER integration

    Findings are consolidated into the Clinical Evaluation Report and regulatory documentation.

Confidential Class III programme

Clinical evidence and PMCF strategy for an implantable neurostimulation submission

Eclevar contributed to the evidence strategy, anticipated Notified Body questions and post-market evidence architecture for a confidential Class III programme.

View the verified contribution
Likely Notified Body questions
Eclevar contribution
QuestionIs the existing clinical evidence sufficient for the claimed indication and population?
ContributionEvidence strategy: what the current dataset supports, where it stops, and what has to be generated.
QuestionIs the long-term benefit of the therapy demonstrated over the device's service life?
ContributionDeficiency anticipation: the long-term benefit argument drafted before the question is asked, not after.
QuestionHow is a responder defined, and is that definition justified for this indication?
ContributionDataset requirements: the variables and timepoints needed to support whichever definition is adopted.
QuestionHow is variability in stimulation settings and programming accounted for?
ContributionData architecture: structured capture of settings, programme changes and device configuration.
QuestionIs the post-market clinical follow-up plan adequate for a Class III active implant?
ContributionPMCF architecture and CER integration: follow-up designed to feed the clinical evaluation it supports.

Eclevar's role was advisory. No regulatory outcome is claimed: conformity assessment decisions belong to the manufacturer and the Notified Body.

Illustrative model

A structured long-term evidence model for an implantable neurostimulation system

View the model

An illustrative architecture, not a completed engagement. It shows how Eclevar would structure a multi-year post-market clinical follow-up programme for a neurostimulator already on the European market, where the clinical evaluation report needs long-term benefit and device performance data.

No patient numbers, timelines or outcomes are given, because none exist. Any figures in a proposal would be derived from your device, your indication and your installed base.

Study type
Prospective multicentre PMCF study with a registry backbone
Population
Consecutive patients implanted at participating centres
Core dataset
Indication, implant details, stimulation settings, outcome instrument, device events
Follow-up
Structured to the device's expected service life, with retention planned from the outset
Outputs
PMCF evaluation report feeding the clinical evaluation report update

Programme governance

The team leading evidence strategy and programme delivery.

Eclevar leads clinical evidence strategy, European study delivery, biometrics and regulatory integration. Indication-specific medical oversight is provided by the sponsor's investigators and independent neuromodulation specialists appointed for each programme.

Dr Mark Da Costa

Regulatory evidence strategy

Dr Mark Da Costa

Chief Operating Officer

Clinical evidence strategy informed by first-hand Notified Body review experience, applied to how a Class III clinical evidence dossier is structured and defended.

Scope. Regulatory evidence strategy and Class III dossier architecture.

Dr Nikhil Khadabadi

Implant and surgical pathway methodology

Dr Nikhil Khadabadi

Chief Medical Officer, Orthopaedics and Spine

Class III implantable device methodology and surgical pathway design, including the spinal access, revision and explant workflows a spinal cord stimulation protocol has to specify.

Scope. Class III implant methodology and surgical-pathway design.

Susanne Höfer

European clinical operations

Susanne Höfer

Head of Clinical Operations, DACH region

Implanting-centre qualification, site activation, monitoring strategy and investigator engagement across Germany, Austria and Switzerland.

Scope. European site feasibility, activation, monitoring and close-out.

Meet the delivery team
Charline Petitdemange

Project delivery

Charline Petitdemange

Project Delivery Lead, France and United Kingdom

Programme delivery and cross-functional governance across the clinical, data, writing and quality workstreams.

Sébastien Meier Piantanida

Data and biometrics

Sébastien Meier Piantanida

Chief Data Officer · Head of Biometrics

Electronic data capture design for stimulation settings and device configuration, database governance, statistics and the analysis-ready dataset.

Pierre-Marie Boutanquoi

Medical writing

Pierre-Marie Boutanquoi

Head of Medical Writing

Clinical investigation reports, clinical evaluation reports and PMCF evaluation reports, plus Notified Body response handling.

Former positions are stated for biographical context only. Eclevar MedTech is an independent contract research organisation. It is not affiliated with, accredited by or endorsed by any Notified Body, and Notified Body names referred to on this site are the trade marks of their respective owners. Notified Bodies issue certificates; individual reviewers assess technical documentation and clinical evidence.

Regulatory, clinical and device frameworks considered

  • Regulation (EU) 2017/745
  • ISO 14155:2026
  • ISO 14708-3:2017 (implantable neurostimulators)
  • Applicable MDCG clinical investigation guidance
  • Regulation (EU) 2016/679 (data processing)
  • Validated electronic systems, where applicable

These are the frameworks Eclevar works to when planning and delivering a clinical investigation. ISO 14708-3:2017 is a device standard applying to the manufacturer's implantable neurostimulator, not a certification held by a contract research organisation, and the applicable part depends on the device concerned. Quality management system certification, electronic system validation scope and data-processing responsibilities are stated per engagement.

Evidence resources

Clinical evidence and insights.

Eclevar's neuromodulation capability is supported by established European clinical operations, biometrics, medical writing and regulated clinical-data infrastructure developed across high-risk medical device programmes.

Institutional validation

Platinum Award, xShare and the European CRO Federation, "EHDS and Clinical Research" Open Call

Awarded to Eclevar MedTech and its Milo Health platform · EUCROF 2026, Amsterdam, 2 February 2026 · Horizon Europe, Grant Agreement No. 101136734 · a clinical data and research platform award, not a neuromodulation award.

Cover of the BSI and Eclevar MedTech whitepaper on EU MDR post-market clinical follow-up

Whitepaper · BSI and Eclevar · Published

Post-market clinical follow-up under EU MDR

Co-authored with Notified Body BSI: a practical reading of the clinical evidence expectations for post-market clinical follow-up under Regulation (EU) 2017/745. It addresses high-risk devices generally and is not specific to neuromodulation.

Neuromodulation evidence design series In development

Planned practical resources covering endpoint design, stimulation-data capture and revision, explant and device-deficiency reporting.

FAQ

Questions neuromodulation sponsors ask.

How do you select European centres for an implantable neurostimulation study?

Start from the indication rather than from the centre's reputation. The question is how many patients matching your inclusion criteria that centre implanted in the last twelve months, whether the multidisciplinary team your protocol assumes actually exists there, and who has the capacity to programme and follow up study patients alongside routine care.

Eclevar runs the feasibility questionnaire, the qualification visits and the activation tracking in-house, and reports the competing studies already open at each centre, because in neuromodulation the best sites are usually already committed.

What evidence is needed for a first-in-human neurostimulation system?

A first-in-human investigation has to establish that implantation and stimulation can be delivered safely in the intended population, and that the device performs as designed. It is characterisation, not confirmation: the endpoints are usually procedural success, device performance, adverse event profile and early tolerability, with clinical effect measured descriptively.

The preclinical package, the risk analysis and the benefit-risk argument have to support it before submission. Eclevar prepares the clinical investigation plan, the investigator brochure input and the competent authority and ethics committee submissions.

How should patient selection and responder definitions be specified?

Both have to be argued for the specific indication, and both have to be fixed before enrolment. A responder threshold that is well established in one chronic pain population does not transfer automatically to another indication, another outcome instrument or another follow-up horizon, and a threshold adopted by convention rather than by justification is a predictable source of Notified Body questions.

The practical approach is to set out the candidate definitions, their published basis and their effect on sample size, and to have the sponsor and the investigators choose on the record.

How are stimulation settings and device configurations captured?

In structured fields, not in free text. Amplitude, frequency, pulse width, active contacts, programme identifier and the date and reason for each change should all be queryable, so that the analysis can describe what was actually delivered rather than what was prescribed.

Where the device or programmer can export its own configuration record, that export should be reconciled with the electronic data capture record rather than transcribed by hand.

What should PMCF collect for an implantable neurostimulator?

Sustained clinical benefit, device performance over time and the full reoperation picture: lead migration and fracture, connector and extension issues, infection, battery depletion, recharge burden, revision and explant, each with its date and reason.

The plan follows the MDCG 2020-7 template and the results are reported in a PMCF evaluation report using MDCG 2020-8. The follow-up period should reflect the device's expected service life rather than the convenience of the reporting cycle.

How should lead, battery, revision and explant events be reported?

Against an event taxonomy defined before first patient in, and reconciled with the sponsor's vigilance and complaint-handling terminology so that the same event is not coded three different ways in three different systems.

Sites need training against that taxonomy, because reporting conventions differ between centres and inconsistent coding is one of the most common reasons a post-market dataset cannot answer the question asked of it.

When does an indication expansion require sponsor-led clinical evidence?

When the intended purpose changes. If the new indication takes the device outside the population, the anatomical target or the clinical claim covered by the existing clinical evaluation, the manufacturer generally needs its own clinical data rather than a body of investigator-initiated work it does not control.

Investigator-initiated studies can be valuable, but whether their data can later support a clinical evaluation depends on how sponsorship, data ownership and data capture were structured at the outset. That decision cannot be retrofitted.

How are software, algorithm or waveform changes assessed?

By asking whether the change affects the device's intended purpose, its safety or its performance. If it does, it is a significant change and needs its own evaluation, and possibly its own clinical data, before it is deployed to patients.

In a study, the practical requirement is traceability: which algorithm or firmware version each patient was on, when it changed, and whether any endpoint data spans a version boundary. Closed-loop systems make this harder, because part of the therapy itself is in the software.

Can European evidence support a global regulatory strategy?

Often, but only if it is planned that way. Study conduct to ISO 14155:2026 is broadly recognised, and a European dataset can contribute to submissions in other jurisdictions where the population, the endpoints and the comparator are acceptable to the reviewing authority.

What decides it is usually whether the target market's expectations were built into the protocol at the start. Retrofitting a European pivotal study to a different jurisdiction's expectations after database lock rarely works.

When is a registry sufficient and when is a prospective clinical investigation required?

A registry suits questions about long-term performance, device survival and real-world use in a population already receiving the therapy, where the clinical benefit is established and the question is durability and safety at scale.

A prospective clinical investigation is required where the benefit itself is the question: a new device, a new indication, a new stimulation strategy, or any claim that needs a controlled comparison. In practice many neurostimulation programmes need both, sequenced so the registry extends the investigation rather than substituting for it.

Start the conversation

Planning an implantable neurostimulation programme in Europe?

Share the system type, indication, development stage, target countries and principal evidence question. Eclevar will identify the clinical strategy, specialist-centre, data, biometrics, PMCF and regulatory workstreams for an initial programme discussion.

Everything you send is treated as confidential. If you would rather start under a non-disclosure agreement, say so in the form and we will send ours before you share anything further.

Send your programme details

Tell us the system type, indication, development stage, target countries and your principal evidence question. You can attach a protocol or synopsis.

Request an evidence review Email clientcare@eclevar.com

Reforming Clinical Evaluation of Medical Devices in Europe