The Crosswalk

    Head to head

    Flag of United States FDA 524BvsFlag of South Korea MFDS

    United States and South Korea medical-device cybersecurity, compared.

    Last updated ·

    Bottom line

    MFDS's 2024 cybersecurity notification is broadly aligned to FDA §524B at the principles level — same lifecycle expectations, same threat-model and SBOM logic. Plan on ~65% reuse: the real costs are Korean-language documentation, a Korean Licence Holder (KLH), K-GMP audit, and the 5-year periodic review unique to Korea.

    Who this is for · US-cleared sponsors planning a Korean MFDS submission.

    Where they differ

    Cyber guidance

    Flag of United States FDA 524B

    FDA Final Guidance (Feb 2026).

    Flag of South Korea MFDS

    MFDS Cybersecurity Review Guideline (rev 2024).

    Takeaway

    Same principles; MFDS adds an AI/ML-specific addendum.

    SBOM

    Flag of United States FDA 524B

    Mandatory (machine-readable).

    Flag of South Korea MFDS

    Recommended; aligns to IMDRF N60.

    Takeaway

    Single CycloneDX file works for both filings.

    QMS

    Flag of United States FDA 524B

    QMSR (ISO 13485:2016).

    Flag of South Korea MFDS

    K-GMP audit (separate from MDSAP).

    Takeaway

    K-GMP is Korea-specific; MDSAP is not accepted.

    Periodic review

    Flag of United States FDA 524B

    None.

    Flag of South Korea MFDS

    5-year re-evaluation required.

    Takeaway

    Budget for a recurring cyber-evidence refresh every 5 years.

    Full profile

    Flag of United StatesUnited States

    FDA Premarket Cybersecurity Guidance & FD&C §524B

    Open profile

    Full profile

    Flag of South KoreaSouth Korea

    Cybersecurity Review Guideline for Medical Devices

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    Frequently asked

    Does MFDS accept FDA clearance?

    Not as a substitute. MFDS runs its own review and requires Korean-language documentation, K-GMP audit, and a Korean Licence Holder. FDA evidence accelerates the technical review but doesn't shortcut the regulatory pathway.

    What's special about MFDS AI/ML expectations?

    MFDS's 2023 AI/ML addendum requires a change-control plan in the submission — similar in spirit to FDA's Predetermined Change Control Plan but with Korean-specific labelling for AI-driven outputs.

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