


EUDAMED Continuity and Demonstrability as Structural Requirements
EUDAMED Governance
Publication is an event.
Continuity is a structure.
EUDAMED compliance depends on the ability to demonstrate aligned regulatory data across evolving devices, certification states, and SRNs.
- New or Evolution of Certificates
- Devices are modified within the regulatory lifecycle.
- Regulatory data is prepared and validated across teams.
- Certification statuses evolve within the regulatory lifecycle.
Regulatory Exposure and Demonstrability
Regulatory inspections may require structured demonstration of alignment, traceability, and historical data states, including:
New or Evolution of Certificates
Renewals, scope changes, or re-certifications must remain aligned with associated devices.
Certificate-device coherence should be demonstrable at any stage.Basic UDI-DI & UDI-DI Alignment
The exact state of a Basic UDI-DI and its linked UDI-DI may need to be retrieved at a specific date.
Historical alignment must be accessible without reconstruction.The justification of modifications
Device updates and data adjustments must be documented and traceable.
Each modification should remain linked to its regulatory context.Timestamped publication records
Submission events and updates must remain timestamped and retrievable.
Demonstrability depends on structured publication history.


Regulatory continuity requires structured traceability.
If historical reconstruction relies on fragmented tools or manual consolidation, demonstrability becomes structurally dependent on coordination.
Structured Governance Enables EUDAMED Continuity
Each regulatory change impacts interconnected records across certificates, devices, and UDI structures.
EUDAMED data evolves continuously
Explicit Certificate ↔ Device Linkage
Certificate renewals, scope changes, and updates must remain structurally connected to associated devices. Relational modeling preserves alignment across certification states.
Basic UDI-DI ↔ UDI-DI Structure
Identifier hierarchies must remain consistent when devices evolve or portfolios expand. Governance maintains controlled alignment across linked UDI levels.
Publication State Control
Draft, submitted, and published states must reflect the current validated data structure. Transitions remain synchronized across all impacted records.
Historical traceability
Each regulatory update must remain retrievable within its historical context. Traceability enables demonstrable continuity across lifecycle events.
Structured Self-Assessment of Your EUDAMED Governance Model
A practical self-evaluation may include the following questions:
Centralized structure ensures alignment…
Do you operate a unified regulatory repository across all SRNs?
A centralized repository ensures consistent data alignment across multi-entity and multi-SRN structures.
Are certificate-to-device relationships explicitly modeled?
Certificates and associated devices should be structurally linked rather than coordinated manually.
Are publication states consolidated across entities?
Draft, submitted, and published states should remain synchronized across all SRNs and internal entities.
Sustainable continuity depends on structured architecture.
Can you retrieve historical states at any specific date?
Historical data states should be accessible at any given date without reconstruction from dispersed records.
Is modification history timestamped and preserved?
Each regulatory update should remain documented with clear timestamps and contextual traceability.
Does governance rely primarily on manual coordination?
Operational alignment should not replace system design. Architecture should embed consistency by default.
When governance relies on coordination rather than structure, continuity becomes operationally fragile.
Download the EUDAMED Compliance Guide
A structured reference to understand the EUDAMED modules, UDI identifiers (UDI-DI & Basic UDI-DI), data integrity requirements, and implementation options.

Basic UDI-DI and UDI-DI Evolution Require Structured Alignment
Basic UDI-DI structures, device records, and publication states evolve together. Regulatory continuity depends on maintaining controlled alignment across these interconnected elements.
Device record updates
Device attributes, configurations, or intended use may evolve. All linked regulatory identifiers must remain structurally aligned within the data model.
Basic UDI-DI adjustments
Changes to Basic UDI-DI structure may impact linked UDI-DIs and associated certificates. Identification hierarchies must remain structurally consistent.
Publication state review
Technical files, scope definitions, and internal references must remain consistent with structured regulatory data. Alignment must extend beyond EUDAMED entries.
Internal documentation updates
Technical files, scope definitions, and internal references must stay consistent with regulatory data. Alignment must extend beyond EUDAMED entries.
One regulatory event affects multiple interconnected data layers
These impacts rarely occur in isolation.

Alignment must be maintained continuously.
Continuity depends on architectural control across certificates, UDI structures, and publication states. Structured governance embeds this control within the regulatory framework.
The Structural Architecture of EUDAMED Governance
In multi-SRN and multi-entity environments, regulatory data must operate as a structured system.
Continuity depends on architectural alignment across identifiers, entities, and lifecycle events.
Structured governance rests on four core components.
Centralized Regulatory Repository
In multi-SRN and multi-entity environments, regulatory data tends to fragment across systems and teams. A centralized regulatory repository establishes a unified structural reference model that governs identifiers, lifecycle states, and cross-entity alignment.
- Basic UDI-DI structural management
- UDI-DI lifecycle control
- Controlled regulatory updates
- Structured device attribute management
- Multi-entity and multi-SRN consolidation
- Referential consistency across identifiers

Certificate-to-Device Coherence
Certificates naturally evolve. Each evolution impacts associated devices and previously published data.
Structured governance requires:- Explicit linkage between certificates and devices
- Controlled update logic
- Prevention of orphaned relationships
- Multi-entity consolidation

Demonstrability Over Time
Compliance is not only about present accuracy.
It includes the ability to:- Demonstrate alignment at a past date
- Demonstrate alignment at a past date
- Preserve modification history - Maintain timestamped traceability
- Multi-entity consolidation

Consolidated Multi-SRN Visibility
In distributed organizations, each entity may act independently within EUDAMED.
Governance requires:- Consolidated view across SRNs
- Portfolio-wide visibility
- Coordinated updates
- Multi-entity consolidation

ACKOMAS and Structured EUDAMED Data Governance
ACKOMAS does not add complexity. It embeds structure into EUDAMED operations.
Centralized Basic UDI-DI and UDI-DI management
Structured management of Basic UDI-DI and linked UDI-DIs within a single controlled reference model, ensuring consistency across identifiers and lifecycle events.
Explicit certificate ↔ device linkage
Formalized certificate-to-device relationships prevent orphaned records and ensure controlled propagation of regulatory changes.
Historical traceability
Version-controlled data architecture enabling reconstruction of regulatory states at any given date, with preserved modification history.
Publication & lifecycle state control
Unified visibility across multiple SRNs and legal entities, enabling portfolio-wide oversight and cross-entity alignment.
Multi-SRN consolidation
Unified visibility across multiple SRNs and legal entities, enabling portfolio-wide oversight and cross-entity alignment.
M2M Submission
Native machine-to-machine submission built on a controlled data architecture, eliminating manual synchronization risks.
The objective is not to automate isolated publication events, but to organize regulatory continuity and demonstrability over time.
Technical Discussion on Your Governance Model
Structured governance organizes regulatory data across entities and certificates. Demonstrability ensures that alignment can be proven at any point in time. Multi-SRN continuity maintains coherence across evolving portfolios.
If EUDAMED continuity, traceability, or multi-SRN alignment are strategic concerns in your organization, we can organize a structured review.

Your current data architecture
Structural assessment of identifier models, lifecycle states, and cross-entity consistency.
Certificate-device linkage model
Formal modeling of certificate-to-device relationships and impact propagation logic.
Historical traceability logic
Version control architecture enabling demonstrable regulatory alignment over time.
Multi-SRN visibility structure
Portfolio-wide oversight and structured multi-entity governance control.
