Regulatory·27 October 2025·12 min

Regulatory Status: EU MDR Class IIa

What our classification actually means, what it does not mean, and what we are working toward in 2026.

K. Lindqvist · Head of Regulatory
Regulatory Briefing

BSerum's clinical formulation is registered as an EU MDR Class IIa medical device. The AI Guardian is a separately conformity-assessed software-as-a-medical-device (SaMD) component under the same regulation. Our Geneva and Zurich clinics operate under ISO 13485 quality management, and our notified body conducts unannounced audits at a frequency we are required to disclose to patients.

Clinic operationsISO 13485 · ISO 27001Software (AI Guardian)MDR Class IIa · IEC 62304Device (formulation)MDR Class IIa · Annex IIPost-market surveillanceregistry · PMCF
Figure 1 — The conformity stack: device, SaMD, QMS, and clinic operations, each with its own annex of MDR documentation and its own audit cadence.

1. What Class IIa means

Class IIa is a medium-risk classification appropriate for therapeutic and diagnostic devices that involve transient or short-term contact with the patient and pose a defined but manageable risk profile. It requires CE marking, technical documentation under MDR Annex II, and post-market clinical follow-up — all of which we file.

ComponentClassificationStandard
Formulation (peptide)MDR Class IIaAnnex II, CE-marked
AI Guardian (SaMD)MDR Class IIaAnnex II + IEC 62304
Clinic QMSn/aISO 13485:2016
Information securityn/aISO 27001:2022
Table 1 — What is conformity-assessed, by component

2. What it does not mean

Class IIa is not the same as a pharmaceutical authorisation. BSerum makes no therapeutic indication claim that requires EMA review, and our marketing materials are constrained accordingly. If you have seen anyone — including a partner clinic — describe BSerum as 'approved for' a specific disease state, that is a misstatement and we want to know about it.

3. What is next

In 2026 we open the first prospective registered trial targeting a specific dermatological indication. That filing will require an entirely different regulatory pathway and a year of additional data. We are funded for it.