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Guide · Regulatory

21 CFR Part 11 for Digital Health: Electronic Records, Signatures, and eCOA/Wearable Data

21 CFR Part 11 sets FDA's criteria for treating electronic records and electronic signatures as trustworthy, reliable and equivalent to paper [1]. If your app, eCOA, wearable platform or EDC creates or holds records that an FDA "predicate rule" requires, such as clinical investigation records, Part 11 applies [1][2]. This guide covers what the rule requires, how FDA enforces it, and a checklist for startups.

Format
Guide
Read time
7 min
Checked
October 27, 2026

Facts checked October 27, 2026.

When does Part 11 apply?

Part 11 applies to records in electronic form that must be kept or submitted under other FDA regulations (the predicate rules) [1]. FDA's 2003 Scope and Application guidance interprets this narrowly. It focuses on records that are required by a predicate rule and that are maintained or relied on electronically [2]. For clinical investigations, FDA's October 2024 final guidance, Electronic Systems, Electronic Records, and Electronic Signatures in Clinical Investigations: Questions and Answers, covers EDC, DHTs and eCOA [3].

What does FDA enforce today?

Under the Scope and Application guidance, FDA intends to exercise enforcement discretion for certain Part 11 requirements: validation, audit trails, record retention and record copying. FDA does, however, still enforce the predicate rules [2]. FDA notes that "part 11 remains in effect" and that the discretion is limited to what the guidance identifies [2]. Access controls, signature controls and the other requirements still apply.

What are the key requirements?

Controls for closed systems (§ 11.10) [1]:

Other sections:

Checklist for eCOA, wearable and EDC startups

How PAHL helps

Palo Alto Health Labs helps teams design audit-ready data architecture for eCOA, wearable and research platforms:

We draw on hands-on experience building clinical research platforms. We don't certify compliance or replace your QA or regulatory function. Book a 30-minute scoping call.

Sources (accessed October 27, 2026)

  1. eCFR, 21 CFR Part 11, Electronic Records; Electronic Signatures: https://www.ecfr.gov/current/title-21/chapter-I/subchapter-A/part-11
  2. FDA, Part 11, Electronic Records; Electronic Signatures — Scope and Application (August 2003): https://www.fda.gov/regulatory-information/search-fda-guidance-documents/part-11-electronic-records-electronic-signatures-scope-and-application
  3. FDA, Electronic Systems, Electronic Records, and Electronic Signatures in Clinical Investigations: Questions and Answers (October 2024, final): https://www.fda.gov/regulatory-information/search-fda-guidance-documents/electronic-systems-electronic-records-and-electronic-signatures-clinical-investigations-questions

Frequently asked questions

Is Part 11 still in force?

Yes. FDA states that "part 11 remains in effect," with enforcement discretion for specified requirements.

Does a consumer wellness app need Part 11?

Not unless it creates or holds records required by an FDA predicate rule, for example when it is used in a clinical investigation.

Do I need to notify FDA about e-signatures?

Yes. § 11.100(c) requires a certification signed by hand and submitted to FDA.

Are electronic signatures and biometrics allowed?

Yes. §§ 11.200 and 11.300 set the controls.

Related

Questions

Is Part 11 still in force?

Yes. FDA states that "part 11 remains in effect," with enforcement discretion for specified requirements.

Does a consumer wellness app need Part 11?

Not unless it creates or holds records required by an FDA predicate rule, for example when it is used in a clinical investigation.

Do I need to notify FDA about e-signatures?

Yes. § 11.100(c) requires a certification signed by hand and submitted to FDA.

Are electronic signatures and biometrics allowed?

Yes. §§ 11.200 and 11.300 set the controls.