Health & Biotech

Software as a medical device (SaMD)

Also known as: SaMD, medical device software

Software as a medical device (SaMD) is software intended to diagnose, prevent, monitor, or treat a medical condition without being part of a physical medical device.

Examples include an app that detects atrial fibrillation from a smartwatch's data or an AI tool that flags strokes on brain scans. While a fitness app and a diagnostic app can look identical on your phone, regulators treat them very differently based on what the software claims to do.

Software as a medical device (SaMD), explained at three levels

At home

Think of the difference between a bathroom scale and a doctor's diagnosis. A step-counting app is like the scale: it reports numbers. Software becomes a medical device when it acts more like the diagnosis, claiming to detect, treat, or monitor a disease. SaMD is software that does that job on its own, on a phone, computer, or cloud server, without being part of a physical device, so regulators review it before it can be sold.

At work

SaMD is software whose intended purpose is medical, such as diagnosing a condition, guiding treatment, or monitoring a disease, and which runs independently of any hardware device. Regulators, including Health Canada and the FDA, treat it as a medical device. For a business, that classification decides whether a product needs clinical evidence, a quality management system, and a licence before sale, which shapes budgets, timelines, and marketing claims.

Real-world examples

At home

Jerome's smartwatch alerted him to a possible irregular heart rhythm. His doctor explained that the watch's ECG feature was a regulated medical device function, unlike its sleep score, and ordered a follow-up test that confirmed atrial fibrillation.

At work

Aisha is the regulatory lead at a Montreal startup building an AI tool that reads skin photos. Because the tool suggests possible skin cancers, it counts as SaMD, so her team is collecting clinical evidence and preparing a Health Canada licence application.

Common confusions

  • All health apps are medical devices. — Only software intended for medical purposes, such as diagnosis or treatment, is regulated as a device.
  • Software inside a physical device is SaMD. — SaMD is standalone. Software that runs a physical device, like a pacemaker's firmware, is regulated as part of that device.
  • Once approved, an AI device can be updated freely. — Significant changes usually need new review unless covered by an approved change control plan.

For analysts

Product teams should write the intended-use statement as early as the first prototype. I'd run every marketing claim past regulatory review, because a single sentence like 'detects disease' can turn a wellness app into a regulated device.

History & origin

Software inside devices, like pacemakers and infusion pumps, has been regulated for decades. As smartphones and cloud computing spread, regulators needed rules for standalone medical software. The International Medical Device Regulators Forum (IMDRF), which includes Health Canada and the US FDA, defined SaMD in 2013 and published a risk framework in 2014. The FDA cleared Apple Watch's ECG app in 2018, and the number of FDA-authorized AI-enabled devices grew past 1,000 by the mid-2020s, most in radiology. In late 2024, the FDA finalized guidance on 'predetermined change control plans' so AI devices could update under pre-agreed rules, and Health Canada followed with final guidance for machine learning-enabled medical devices in early 2025. In my view, SaMD regulation is where the 'move fast' culture of tech meets the 'first, do no harm' culture of medicine.