Why PMCF is Mandatory Under EU MDR 2017/745 | Annex XIV Part B Guide | Eclevar MedTech
PMCF · EU MDR 2017/745 · Annex XIV Part B

Why PMCF is mandatory under EU MDR 2017/745.

Post-market clinical follow-up is no longer a nice-to-have. Understand your exact obligations under Annex XIV Part B, explore the PMCF methodologies, and keep your CE mark and technical documentation compliant.

Annex XIV Part B PMCF surveys Observational & registry PMCF PMCF Plan
Eclevar MedTech receiving the Platinum Award at the xShare and EUCROF Open Call Awards for Clinical Research in Amsterdam Platinum Award 2026

Eclevar MedTech and Milo took the Platinum Award at xShare & EUCROF.

Top prize in the xShare x European CRO Federation "EHDS & Clinical Research" Open Call, awarded to Eclevar MedTech and its Milo Health platform, presented at the EUCROF 2026 conference in Amsterdam.

Co-funded by the European Union

Horizon Europe · Grant Agreement No. 101136734 · Amsterdam, 2 Feb 2026

Trusted by medical device manufacturers

Manufacturers who keep their CE mark.

Device leaders rely on Eclevar for proactive PMCF that keeps their technical documentation compliant. Read all client success stories.

TERUMO Meril NIHON KOHDEN VYGON Coloplast SHOFU ASAHI INTECC RegenLab TERUMO Meril NIHON KOHDEN VYGON Coloplast SHOFU ASAHI INTECC RegenLab
Dr Mark DaCosta, COO at Eclevar MedTech and former TÜV SÜD Notified Body reviewer
Dr Mark DaCosta COO · Former Notified Body reviewer Former reviewer at TÜV SÜD
Written by former reviewers

A PMCF Plan drafted the way a reviewer assesses it.

Under EU MDR, a PMCF Plan is judged on whether every activity maps back to the gaps in your Clinical Evaluation Report. COO Dr Mark DaCosta, a former TÜV SÜD reviewer, leads a team that has assessed these files from inside a Notified Body, so your plan is built to answer the questions before they are asked.

Ex NBFormer TÜV SÜD reviewer
Annex XIVPart B, gap-mapped plans
Benefit-riskISO 14971 integration
PMCF Plan & Report PSUR & CER Class III & AIMD
LinkedIn
Aligned to EU MDR 2017/745 Annex XIV Part B ISO 14155:2026 ISO 14971 ISO 13485 GDPR
The legal mandate

PMCF is a continuous, proactive duty.

Annex XIV Part B explicitly defines PMCF as a continuous, proactive process that updates the Clinical Evaluation Report. It is not something you do once, and it cannot be replaced by reactive complaint handling.

What PMCF must achieve
  • Confirm safety and performance throughout the device lifetime.
  • Identify previously unknown side-effects.
  • Identify and analyse emergent risks based on real evidence.
  • Keep the benefit-risk ratio acceptable, integrated with ISO 14971.

"Under EU MDR, absence of evidence is not evidence of safety. If you are not proactively collecting clinical data on your device in the real world, your technical documentation is considered fundamentally non-compliant."

The reviewer's default position
Obligations by device class

What is expected, class by class.

Device classPMCF obligation and expectationTypical evidence strategy
Class I & IIaPMCF required. A manufacturer may justify not running a new study if PMS and literature data are robust and well documented.PMCF surveys (physician and patient PROMs), literature reviews, structured PMS.
Class IIbA proactive PMCF study is generally expected. Any justification not to run one, such as well-established technology, must be documented.Structured surveys, retrospective EHR data, lightweight observational studies.
Class III & implantablesStrictly mandatory. Absence of a proactive programme can mean certification suspension.Prospective observational studies, European registries, longitudinal PROMs.
The methodologies

Four ways to build PMCF evidence.

Not every programme needs a clinical investigation. The right activity depends on your device class, indication and the unresolved data gaps in your CER.

01

PMCF surveys

The most cost-effective option for Class I to IIb: physician and patient surveys with validated instruments and genuine regulatory weight.

Discover PMCF surveys ›
02

Observational studies

Prospective PMCF using the MILO EDC platform to capture real-world safety and performance data across European sites.

Explore observational PMCF ›
03

Registry strategy (RWE)

Extract real-world evidence from national registries such as the NJR, EPRD and Swespine, mapped to your regulatory claims.

Read the registry guide ›
04

The PMCF Plan

Strategic documentation drafted by a team that includes a former Notified Body reviewer, mapped directly to your CER data gaps.

Master the PMCF Plan ›
Official content

Our content, signed Eclevar.

Whitepapers, client testimonials and publications produced by our teams and partners (BSI, TÜV SÜD, RegenLab).

Whitepaper by BSI and Eclevar on the EU MDR
Whitepaper · BSI × Eclevar

A BSI and Eclevar whitepaper on the EU MDR.

Written with Notified Body BSI: a practical reading of the clinical evidence expectations under EU MDR 2017/745, the same expectations your PMCF has to satisfy.

PMCF Studies · Regenerative Medicine · 5 EU Countries

A client's live testimonial on Eclevar's capability to run complex trials.

Eclevar manages RegenLab's PMCF programme on chronic wound devices. This is a randomized study of 160 patients across 14 sites in 5 EU countries, covering both diabetic foot ulcer (DFU) and venous leg ulcer (VLU) indications, combining Eclevar's ISO 14155 clinical expertise with the Milo Studio platform.

« Eclevar, with its tailor-made approach and advanced Milo Studio platform, represents a major strategic asset. »Antoine Turzi, CEO, RegenLab
160patients · 14 sites
5EU countries
RegenLab video testimonial on the PMCF programme managed by Eclevar
FAQ

Why PMCF matters, answered.

Why is PMCF mandatory under EU MDR?

Passive, reactive surveillance is not sufficient under EU MDR. PMCF is a continuous, proactive process required by Annex XIV Part B to confirm a device's safety and performance throughout its lifetime, identify emergent risks and keep the benefit-risk ratio acceptable, feeding directly into the Clinical Evaluation Report.

Can we justify not conducting a PMCF study?

For low-risk devices (Class I and IIa), a manufacturer may justify not running a new study if existing PMS and literature data are robust, but that justification must be heavily documented. Class IIb and Class III devices generally require proactive PMCF studies.

What are the typical PMCF activities?

Physician and patient surveys with validated PROMs, prospective observational studies, and real-world evidence extracted from national registries such as the NJR, EPRD and Swespine, all governed by a formal PMCF plan.

What happens if a Class III device has no PMCF?

For Class III and implantable devices, PMCF is strictly mandatory. Absence of a proactive PMCF programme means the technical documentation is considered fundamentally non-compliant, which can lead to certification suspension.

Who should write the PMCF plan?

Ideally, people who have assessed these files from the other side. Eclevar's PMCF plans are drafted by a team that includes a former Notified Body reviewer, so each activity is mapped to the CER data gaps a reviewer will look for.

Guaranteed response within 24 hours

Turn a PMCF obligation into a defensible plan.

Tell us about your device and its class. We will map your Annex XIV Part B obligations to the right activity mix and give you a clear, costed PMCF plan.

Book a free strategy call

Reforming Clinical Evaluation of Medical Devices in Europe