Compliance & Regulation

"We did a pentest" no longer satisfies medical device regulators

Penetration testing has been a cornerstone of medical device security for years. Regulatory expectations have outgrown the report-centric model. A single point-in-time test cannot demonstrate the thing regulators now ask for, which is completeness and traceability across the whole product, not a snapshot of whatever a tester happened to reach that week.

Point-in-time pentestone tester, one windowReporta PDF of findingsGapsno coverage mapRegulator asksprove completeness
The legacy model ends where the regulator's question begins.

This is not a knock on penetration testing. Human-driven testing is still essential. It has to be repositioned as a targeted validation activity inside a broader, test-case-driven framework that ties findings to architecture and security controls, with evidence of execution and a full history across releases.

Why the old model breaks on products

Senior testers are expensive. Expanding manual testing to the level of completeness a medical device needs, on every release, forever, is not economically viable. Postmarket makes it worse, because testing is expected to recur. The math does not work with people alone.

To show diligence now, manufacturers are expected to provide a complete inventory of test cases, traceability to architecture and controls, evidence of execution with pass or fail criteria, and a full history of what was found and fixed across development. That is a systems problem, not a report.

The question is not whether you tested. It is whether you can show what you covered, what you did not, and why.

The programs that hold up under review treat the security testing function as software that lives where the device is built and produces verdicts with evidence. The pentest becomes one input, not the whole story.

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