EU MDR · ISO 14155 · Pre-market

Pre-market clinical investigations, built for Notified Body approval.

For high-risk devices, literature and equivalence no longer clear the bar. A well-designed pre-market study is often the only route to CE mark. Here are the four pillars and when you need one.

EU MDR Annex XVISO 14155EUDAMED & SRNGDPR & Helsinki
Pre-market clinical investigation under EU MDR and ISO 14155, Eclevar MedTech

European Champion

Platinum Award 2026

Eclevar MedTech & Milo Health · xShare × EUCROF Open Call

Led by authority

Protocols designed by clinical and regulatory specialists.

A pre-market study that clears review is designed by people who know how Competent Authorities and Notified Bodies read a protocol.

Pierre-Marie Boutanquoi

Pierre-Marie Boutanquoi

CMO & Head of Medical Writing · 15+ yrs

Clinical investigation plans, Annex XV compliance and Competent Authority submissions under EU MDR.

in LinkedIn
Charline Petitdemange

Charline Petitdemange

Lead Clinical Project Manager

ISO 14155 study conduct, EUDAMED registration and multi-country monitoring.

EU MDR Annex XVISO 14155GDPREUDAMED / SRN

Awards, funding, accountability

Europe’s best-rated medical device CRO.

Platinum Award 2026

Platinum Award 2026

Top tier at the xShare × EUCROF Open Call, awarded to Eclevar MedTech and its Milo Health platform, presented at EUCROF 2026 in Amsterdam.

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Co-funded by the European Union

Selected through the xShare Open Call for clinical research innovation, Horizon Europe.

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Independently reported

Distinction confirmed by an independent third party, the CVBF, also an awardee of the xShare × EUCROF Open Call.

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The four pillars

Four frameworks. All must hold.

The move from the MDD to EU MDR altered the path to market. A pre-CE mark investigation must satisfy multiple overlapping frameworks — and failure in any single pillar means rejection by a Competent Authority or Notified Body.

Pillar 1

EU MDR Annex XV

Defines the strict legal requirements for clinical investigations in Europe: protocol structure, investigator brochures and sponsor obligations.

Pillar 2

ISO 14155

The core Good Clinical Practice standard for medical devices: how trials must be designed, conducted and recorded.

Pillar 3

GDPR

Patient data protection: pseudonymisation, explicit informed consent and certified health-data hosting (e.g. HDS in France).

Pillar 4

Declaration of Helsinki

The ethical bedrock: patient safety and well-being prioritised over scientific or commercial interests.

When you need a study

By device class.

Not every device needs a new trial. The obligation depends on class and the availability of existing clinical data.

Device classClinical evidence requirementPre-market study?
Class I & IIaClinical evaluation from literature, post-market data of equivalents and bench testing.Rarely — only for novel technology, materials or a new intended purpose with no equivalent.
Class IIbComprehensive CER; equivalence claims heavily scrutinised.Frequently — unless strict biological, technical and clinical equivalence is proven.
Class III & implantablesExceptional scrutiny; Article 61 mandates investigations.Almost always — exceptions are extremely narrow (e.g. legacy transition with robust data).

Crucial regulatory update

EUDAMED registration, before first patient.

Managing an ISO 14155 pre-market investigation is now inextricably linked to EUDAMED. Sponsors and Clinical Project Managers must complete administrative workflows before recruiting a single patient.

Before recruitment

  • Obtain a Single Registration Number (SRN) to identify the sponsor across EUDAMED
  • Register the clinical investigation, including SADE reporting and annual progress reports
  • Align the protocol, the CIP and the submission with the target Competent Authority — see our MDCG 2021-8 guide

Pre-market at a glance

What review now requires.

Annex XV
legal basis for the investigation
ISO 14155
GCP for devices
Class III
Article 61 makes it mandatory
SRN
EUDAMED before first patient

Talk to a specialist

Do you need a pre-market clinical investigation?

Book a free scoping call. We tell you whether your class and data require a study, design the ISO 14155 protocol, and handle the EUDAMED and Competent Authority workflows.

Book a free scoping call

A protocol that fails one pillar fails the whole submission.

An expert read checks your pre-market study against Annex XV, ISO 14155, GDPR and the ethics framework, and confirms the EUDAMED steps, so the file clears Competent Authority and Notified Body review.

Consult our clinical experts

Questions we hear first

Pre-market clinical investigations, answered.

When is a pre-market clinical investigation required under EU MDR?
It depends on device class and available data. Class I and IIa rarely require a new study unless they use novel technology or a new intended purpose without an equivalent. Class IIb frequently requires one unless strict biological, technical and clinical equivalence is proven. For Class III and implantables, Article 61 makes an investigation almost always mandatory.
What frameworks govern a pre-market clinical investigation?
Four overlapping frameworks must all be satisfied: EU MDR Annex XV for the legal requirements, ISO 14155 for Good Clinical Practice for devices, GDPR for patient data protection, and the Declaration of Helsinki for research ethics. Failure in any single pillar leads to rejection by a Competent Authority or Notified Body.
What is the EUDAMED SRN and why does it matter?
The Single Registration Number (SRN) identifies the sponsor across EUDAMED. Managing a pre-market clinical investigation is now inextricably linked to EUDAMED: sponsors must complete registration workflows, including obtaining an SRN, before recruiting a single patient.
Can equivalence replace a clinical investigation?
Reliance on literature and strict equivalence is no longer sufficient for high-risk devices. Equivalence claims for Class IIb and III are heavily scrutinised and must show biological, technical and clinical equivalence, often with contractual access to the equivalent device's technical documentation. Where that cannot be shown, a pre-market study is required.

Reforming Clinical Evaluation of Medical Devices in Europe