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MedTech

Navigating MHRA PMS compliance: Everything UK MedTech manufacturers need to know

As of 16 June 2025, the UK has officially implemented a new regulatory framework for medical device Post-Market Surveillance (PMS), marking a significant shift in how manufacturers must now monitor and report on the safety and performance of their products.

September 01, 20253 Minutes to Read
With insights from
portrait photo of Simon Christopher, Director Med-Tech/ Health-Tech Business at Zühlke

Simon Christopher

Director Med-Tech/ Health-Tech Businesssimon.christopher@zuhlke.com

This change – introduced through the Medical Devices (Post-market Surveillance Requirements) (Amendment) Regulations 2024 – is more than just a regulatory update. It’s a call to action for manufacturers to adopt a proactive, data-driven approach to compliance, safety and innovation.

What does the MHRA PMS regulation mean?

These updated PMS requirements apply to all CE and UKCA-marked medical devices in the GB market, including in vitro diagnostics and active implantable devices. At its core, the framework mandates that PMS must become a proactive process designed to collect and review data from in-use devices – rather than a case of reacting to incidents as they occur. This process must be fully integrated into the manufacturer's overarching Quality Management System (QMS). Key obligations include:

Mandatory PMS Plans (PMSP):

Manufacturers must maintain a written PMSP for all devices, outlining how they will systematically collect, assess and act on post-market data (Reg. 44ZE).

Regular, risk-based reporting:

Depending on device risk class, manufacturers must submit either a Post-Market Surveillance Report (PMSR) for low-risk devices or a more detailed Periodic Safety Update Report (PSUR) for higher-risk devices classified as Class IIa, IIb, and III (Reg. 44ZM).

Faster incident reporting:

Serious incidents must now be reported within 15 working days, a significant reduction from the previous 30-day window (Reg. 44ZH).

Digital vigilance:

All vigilance reporting must be done via the Medicines & Healthcare products Regulatory Agency (MHRA)’s new Manufacturer’s Online Reporting Environment (MORE) platform (Reg. 44ZI). This move toward a centralised, digital system mirrors the approach of established international bodies – like the EU's EudraVigilance – which use standardised electronic reporting for early signal detection and robust safety monitoring.

These changes aim to enhance patient safety, increase transparency and align UK standards more closely with global best practices.

The business impact: Risk, complexity and opportunity

For many organisations, especially SMEs and scale-ups, these new requirements introduce significant operational and technical challenges.

Inefficient post-market processes can be a major resource drain, and that can have knock-on effects on agility, safety and compliance.

Key pressures here include:

  • Increased compliance overhead: The need for detailed PMS Plans and periodic reports for all devices requires dedicated resources and expertise.
  • Need for robust data infrastructure: Tracking device performance in real time requires more than spreadsheets; it demands a secure and scalable data infrastructure.
  • Pressure to align with UK-specific reporting: While the new UK rules are similar to the EU MDR, they’re not identical. One key difference lies in the scope of reporting; EU MDR requires broader market intelligence, including safety data from similar devices by other manufacturers and consideration of the evolving technological landscape. 

In contrast, the UK PMS framework focuses more narrowly on device-specific data from the GB market, and does not mandate inclusion of competitor data or external benchmarks. This divergence prevents a simple "copy and paste" of compliance strategies and calls instead for a modular PMS approach – one that supports deeper reporting in EU submissions and streamlined processes for UKCA-marked devices. The push for real-world evidence is a global trend, with other major regulators like the US FDA also mandating robust post-market data collection for many devices.

However, these challenges also create opportunities. For companies that embed a proactive and efficient compliance strategy into their innovation lifecycle, these regulations can become a source of competitive advantage.

It's also critical to note that these changes are a sign of what’s to come, with future UK regulations expected for areas like software/AI and Unique Device Identification (UDI).

Your immediate compliance checklist

  • 1. Confirm MORE platform access

    Ensure your designated regulatory contact is successfully registered on the MHRA's MORE platform.

  • 2. Audit your portfolio

    Classify every device on the GB market to determine its reporting requirement (PMSR vs. PSUR) under the new framework.

  • 3. Assess your data systems

    Evaluate your current ability to collect, aggregate, and analyse post-market data in a scalable and timely manner.

  • 4. Map your strategy

    Define a clear roadmap for integrating PMS into your QMS and turning compliance data into actionable insights.

How Zühlke can help: Your partner for compliant innovation

At Zühlke, we understand that compliance is not just a checkbox. When done right, it’s a competitive advantage. With deep expertise in regulated industries like HealthTech, we help organisations navigate the highly-specific challenges posed by an ever-evolving regulatory landscape.

Health industry leaders already recognise that technology is critical when it comes to compliance, with 70% reporting that it provides better visibility of risks and 51% confirming it enables a faster response to issues.

We help organisations:

  • Design and implement PMS-ready systems that automate data collection and reporting – ensuring they are integrated directly into your Quality Management System, as expected by approved bodies.
  • Integrate AI-driven monitoring tools to detect safety signals and trends early.
  • Build digital platforms that are secure, scalable and compliant with MHRA and international standards.
  • Navigate regulatory complexity with multidisciplinary teams that combine engineering, strategy and emergent technology skills that modern compliance demands.

In addition, Zühlke helps companies streamline PSUR reporting workflows (as required under Reg. 44ZM), detect safety trends early through AI-supported analysis (Reg. 44ZN) and ensure readiness through regulatory gap assessments aligned with both UK MDR (Reg. 44ZE) and ISO 13485.

For manufacturers developing software or AI-based medical technologies, we also support digital health compliance in line with IEC 62304 – anticipating future guidance for SaMD and AI/ML systems in the UK.

So, whether you're launching a new device or modernising legacy systems, Zühlke offers end-to-end support – from concept to compliance and beyond.

Digital Strategy Consulting

Let’s build what’s next – safely and strategically

The UK’s new PMS regulations are a pivotal moment for the HealthTech sector. They demand more than compliance – they demand innovation built upon resilience, agility and foresight.

At Zühlke, we don’t just help you meet ever-evolving standards. We help you set them.

🔗 Learn more about our work in regulated industries like Healthcare or MedTech.

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