In many cases, a change made solely to strengthen cybersecurity is not likely to require submission of a new 510(k). Cybersecurity updates are considered a subset of software changes that are implemented to strengthen the security of a system, protect information, and reduce disruption in service. FDA expects manufacturers to ensure that such changes do not impact the safety or effectiveness of the device by performing necessary analysis, verification, and/or validation. The manufacturer should refer to FDA’s guidance Content of Premarket Submissions for Management of Cybersecurity in Medical Devices and Postmarket Management of Cybersecurity in Medical Devices for more information.

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