New to the rules? Read the five-question FDA decision guide first.
Answer for one software function at a time. FDA classifies each software function separately (FDA Step 1).
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Draft and educational only. Not legal or regulatory advice, and not an FDA determination. Palo Alto Health Labs is not regulatory counsel or a filer of record.
Related
Questions
Does FDA classify a whole app or each software function?
Each software function. FDA's Step 1 page says to repeat the assessment for each software function in a product.
Can a wellness wearable show blood pressure or SpO2 values?
Under FDA's January 2026 General Wellness guidance, non-invasive wellness products should not display values that mimic clinical ones unless validated, and must avoid disease references, clinical alerts, treatment guidance and clinical-grade claims.
Is 510(k) or De Novo the right pathway for my software?
A 510(k) shows substantial equivalence to a legally marketed predicate device. De Novo is for novel low-to-moderate-risk devices with no legally marketed predicate. A Pre-Submission can get FDA feedback first.