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    GuidanceLast updated · 2023Verified · 2026-07-16

    Cybersecurity Guidance for Medical Devices (2021, rev. 2023)

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    Authority

    Taiwan Food and Drug Administration

    Enforced

    Jul 2021

    Legal framework

    Medical Devices Act + TFDA Cybersecurity Guidance + IMDRF N60 alignment

    FDA package reuse

    ~80%

    Scope

    Network-connected medical devices and SaMD. Risk-based depth of cybersecurity evidence at registration.

    Pre-market

    Threat modelling, secure design, verification & validation; SBOM expected for higher-risk devices.

    Post-market

    Vulnerability monitoring, software change reporting, periodic security updates.

    SBOM

    Required

    Expected at submission for Class II/III network-connected devices; SPDX or CycloneDX accepted.

    Vulnerability disclosure

    TWCERT/CC coordinated disclosure encouraged.

    Penalty

    Licence revocation, recall, fines under Medical Devices Act.

    Unique requirements

    • 01Taiwan Licence Holder required
    • 02Traditional Chinese labelling and IFU
    • 03QSD (Quality System Documentation) inspection

    Highlights

    • Closely tracks IMDRF N60
    • SBOM expected for Class II/III
    • Reference jurisdiction route accepted for FDA approvals

    Aligns with

    IMDRF N60 FDA 2023 Guidance IEC 81001-5-1

    Timeline

    1. Jul 2021

      First cybersecurity guidance

    2. 2023

      Revision aligned to IMDRF N60

    Key documents

    How to submit in Taiwan

    Playbook reviewed · 2026-07-16

    Submission route

    TFDA licence under the Medical Devices Act with cybersecurity per TFDA 2021 guideline

    TFDA aligns with IMDRF and accepts FDA / PMDA content with Chinese translation. Cybersecurity guideline mirrors FDA 2018 pre-market with local adaptations.

    Authority portal

    Step-by-step

    1. Step 01

      Appoint local representation

      Most jurisdictions require a locally-established entity to hold the registration or act as authorised representative before submission.

    2. Step 02

      Reuse FDA or CE package as baseline

      Adapt the cybersecurity subsection you already prepared for FDA or CE; regulators here typically accept the structure and ask for local labeling additions.

    3. Step 03

      Translate and localise

      Local-language technical summary and labeling are usually mandatory; certified translation is safest.

    4. Step 04

      Submit + track queries

      Respond to clarification rounds promptly; each unanswered question can add 30-90 days to the clock.

    Evidence checklist

    Item Level FDA equivalent Notes
    Cybersecurity documentation (baseline FDA or CE) Required SPDF
    Local authorised representative agreement Required
    Local-language labeling and IFU Required
    SBOM Recommended Not mandatory but reduces clarification rounds.

    Common TFDA rejections

    No Taiwanese licence holder

    Common

    Fix · Appoint a Taiwanese entity holding a device permit.

    Typical timeline

    End-to-end window: 6-12 months

    Phase 01

    Local rep + dossier prep

    2-4 months

    Phase 02

    Regulatory review

    6-12 months

    Phase 03

    Approval + market entry

    1-3 months

    Related markets

    Frequently asked about Taiwan

    Is SBOM required for medical devices in Taiwan?

    Required. Expected at submission for Class II/III network-connected devices; SPDX or CycloneDX accepted.

    What does TFDA require for pre-market cybersecurity?

    Threat modelling, secure design, verification & validation; SBOM expected for higher-risk devices.

    What are the post-market cybersecurity obligations under TFDA?

    Vulnerability monitoring, software change reporting, periodic security updates.

    What is the penalty for non-compliance with TFDA cybersecurity rules?

    Licence revocation, recall, fines under Medical Devices Act.

    How much of my FDA cybersecurity package is reusable in Taiwan?

    Roughly 80% - an editorial estimate based on overlapping evidence requirements (threat model, SBOM, security risk assessment, pen-test report).