Full Checklist of Documents for MDA

Full Checklist of Documents for MDA Medical Device Registration Malaysia (2026)

Table of Contents

Quick Answer

MDA registration requires administrative documents (establishment licence, AR declaration, GMDN code), a completed CSDT, ERSP checklist, risk management file, clinical evidence, labelling and IFU, and ISO 13485 certification. Requirements scale by class — Class A submits directly to MDA; Class B, C, and D require a full CSDT and CAB conformity assessment first.

Incomplete documentation is the most common reason MDA submissions are delayed or returned. Not because manufacturers are careless — but because knowing that a CSDT is required is very different from knowing exactly what every section must contain, which annexes apply to your device class, and what the MDA considers a compliant cross-reference.

This guide gives you the full, class-by-class document checklist — built directly from MDA guidance documents MDA/GD/0008 and MDA/GD/0070 (Second Edition, October 2025) — so you know exactly what to prepare before a single document is drafted. For a full walkthrough of the end-to-end process, see our guide on how to register a medical device in Malaysia.

Key Takeaways

  • All device classes require administrative documents — establishment licence, AR declaration, GMDN code, and MeDC@St application form.
  • Class A devices submit directly to MDA with lighter documentation — no CAB required for standard devices, with exceptions for sterile and measuring subtypes.
  • Class B, C, and D require a full CSDT and conformity assessment by a registered CAB before MDA submission.
  • Every CSDT section must be addressed — if a section does not apply, a documented justification for non-applicability is required.
  • All certificates and reports must be signed, dated, and within their validity period at time of submission.
  • Devices already approved by FDA, EU CE, HSA, TGA, or Health Canada may qualify for the expedited Verification Route.
  • Incorrect or missing documentation is closely related to common classification mistakes — getting both right from the start protects your timeline.
Before You Start

Confirm These Two Things First

Before assembling any documents, you need to confirm your device classification and your regulatory pathway. These two decisions determine your exact document set.

Standard pathway
Full conformity assessment

For devices without prior approval from a recognised authority. Requires full CSDT and CAB assessment for Class B, C, and D devices before MDA submission.

Foreign manufacturers must appoint a Local Authorised Representative (LAR) before any submission can be made. The LAR holds the MeDC@St account and submits all documents on your behalf.

Class A

Documents Required for Class A Registration

Class A devices follow a simplified pathway — submissions go directly to the MDA via MeDC@St with no CAB conformity assessment required for standard devices. This is governed by the Medical Device Act 2012 (Act 737). Class A sterile and measuring devices have additional validation requirements beyond the standard list below.

A
Class A — Low Risk
Direct MDA submission · No CAB required (standard devices)
Administrative documents
MeDC@St application formCompleted via the MDA online portalRequired
Establishment licenceLAR, importer, or manufacturer licence issued by MDARequired
AR DeclarationAnnex B format per MDA/GD/0041Required
GMDN codeGlobal Medical Device Nomenclature code for the deviceRequired
GDPMD certificateGood Distribution Practice for Medical Devices certificateRequired
Product listAll models, configurations, and variants to be registeredRequired
Technical documents
Device description and intended useClear statement of medical purpose, indications, and patient populationRequired
ERSP checklistEssential Requirements for Safety and Performance, per MDA templateRequired
Declaration of ConformityMDA format per Appendix 1A, Medical Device Regulations 2012Required
Labelling and IFUAll labels, packaging text, and Instructions for UseRequired
Additional (device subtype dependent)
Sterilisation validationRequired for Class A sterile devices onlyIf sterile
Metrological confirmation recordsRequired for Class A measuring devices onlyIf measuring
Class B

Documents Required for Class B Registration

Class B devices require a full CSDT and must undergo conformity assessment by a registered CAB before the MDA submission. The CAB issues a certificate and assessment report upon successful review — both must be included in your MDA submission package. Unsure which class your device falls into? Read our complete classification guide.

B
Class B — Low to Moderate Risk
CAB assessment required · Full CSDT submission
Administrative documents
All Class A administrative documentsMeDC@St form, establishment licence, AR declaration, GMDN, GDPMD, product listRequired
CAB certificateIssued by a registered Conformity Assessment Body after successful reviewRequired
CAB assessment reportFull assessment report from the CAB, signed and datedRequired
CSDT core sections (MDA/GD/0008)
Executive summaryDevice synopsis, commercial history, summary of CSDT contentsRequired
Device description and intended useIntended use, indications, contraindications, principle of operationRequired
ERSP checklist with cross-referencesEvery applicable EP addressed with method and controlled document referenceRequired
Design verification and validation summarySummary of testing confirming device meets specificationsRequired
Risk management reportISO 14971 risk management fileRequired
Clinical evaluation reportSummary of clinical evidence demonstrating safety and performanceRequired
ISO 13485 certificateValid QMS certification from the manufacturerRequired
Labelling and IFUMust be consistent with CSDT, intended use, and clinical evaluationRequired
Post-market surveillance planPMS strategy for monitoring device performance after approvalRequired
Declaration of ConformityMDA format, Appendix 1ARequired
HS CodeHarmonized System Code for customs classificationRequired
Supporting documents
Reference agency approvalsCE, FDA, TGA, HSA, or Health Canada certificates and approval lettersIf available
Commercial marketing historyList of countries where device is marketed and dates of market entryIf applicable
Class C

Additional Documents Required for Class C

Class C submissions include everything in the Class B list. The following documents are additional requirements at this level, reflecting the higher risk profile and more demanding CAB assessment.

C
Class C — Moderate to High Risk
All Class B documents, plus the following
Full clinical evaluation reportComprehensive data, not a summary — systematic literature review or clinical investigation dataRequired
Post-market clinical follow-up planOngoing clinical monitoring strategy beyond the standard PMS planRequired
Biocompatibility assessmentISO 10993 series — required for all devices with patient contactRequired
Sterilisation validationFor devices supplied sterileIf sterile
Software lifecycle documentationIEC 62304 — for devices containing embedded or companion softwareIf software
EMC test reportsIEC 61000 series — for active devicesIf active
Electrical safety test reportsIEC 60601 series — for electrically powered devicesIf powered
Long-term implant safety dataChronic biocompatibility and fatigue data for implantable componentsIf implantable
Note: Which specific standards apply depends on the device type, intended use, and whether the device is active or non-active. Confirm applicable standards with your LAR before commissioning any testing — incorrect standards selection leads to wasted cost and rework.
Class D

Additional Documents Required for Class D

Class D devices carry the highest risk and require the most stringent documentation. These submissions build on the full Class C list with the following additional requirements.

D
Class D — High Risk
All Class C documents, plus the following
Full clinical investigation dataOr a comprehensive systematic literature review with extended long-term follow-up data — a summary is not sufficient at this levelRequired
Detailed PMS system documentationFull post-market surveillance system — not just a plan, but evidence of the entire monitoring infrastructureRequired
Comprehensive risk-benefit analysisFull ISO 14971 risk management file with an explicit, documented benefit-risk determinationRequired
Vigilance and incident reporting proceduresDocumented processes for reporting adverse events to the MDA post-approvalRequired
Additional manufacturing QA documentationExtended QMS evidence appropriate for life-sustaining or life-supporting device typesRequired
Class D advisory: These submissions involve the most back-and-forth with both the CAB and the MDA. Engage your LAR and regulatory consultant before any documentation is drafted — do not start building a technical file and work backwards to classification.
Inside the CSDT

What Each CSDT Section Must Cover

The CSDT is governed by MDA/GD/0008. Every section must be addressed. If a section does not apply to your device, a documented justification of non-applicability is required — blank entries are not accepted by the CAB or MDA. For IVD devices, additional evidence requirements apply — see our IVD classification guide.

Section 1
Executive summary

Device synopsis, novel features, commercial marketing history, and a summary of CSDT contents. Must be consistent with all other sections throughout the dossier.

Section 2
EPSP checklist

Each applicable Essential Principle addressed with the method used to demonstrate conformity and a cross-reference to the supporting controlled document. Non-applicable principles require written rationale.

Section 3
Device description and intended use

Full description including components, operating principle, indications, contraindications, intended patient population, and intended user. This section drives classification — it must be precise.

Section 4
Design verification and validation

Summary of all testing and validation confirming the device meets its specifications. Full test reports must be available for CAB review on request.

Section 5
Clinical evidence

Clinical evaluation report or performance data. Depth scales with class — summary for Class B, full report for Class C, complete clinical investigation data for Class D.

Section 6
Labelling and IFU

All labels, packaging, and Instructions for Use. Must be consistent with the intended use statement, CSDT, and clinical evaluation. IFU must cover safe use procedures, frequency, duration, and preparation steps.

Section 7
Risk management

ISO 14971 risk management report covering hazard identification, risk estimation, risk evaluation, and risk control measures. A full risk-benefit analysis is required for Class D devices.

Section 8
Manufacturer information

Manufacturing process description, site details, QMS certification (ISO 13485), and authorised signatory details. All certificates must be valid and within their stated validity period.

Common Pitfalls

Six Submission Mistakes That Delay Approval

These documentation pitfalls are closely linked to the broader classification mistakes that delay MDA submissions. Fixing both before submission is the most effective way to protect your timeline.

01
Inconsistent intended use across documents

The intended use in the CSDT, labelling, IFU, clinical evaluation, and MeDC@St application must be identical. Any inconsistency triggers an MDA query and pauses the review clock.

02
Expired certificates at time of submission

ISO 13485, CAB assessment certificates, and reference agency approvals must all be valid at the submission date. Check validity before submitting — not at the point you originally obtained them.

03
Broken or missing CSDT cross-references

Every controlled document referenced in the EPSP checklist must be submitted in full with clear cross-references. Missing or broken links are the most common cause of CAB queries.

04
Vague or blank ERSP checklist entries

Each applicable essential requirement must be addressed with the specific method used to demonstrate conformity. Generic responses and blank entries are not accepted by the CAB or MDA.

05
No justification for non-applicable CSDT sections

If a CSDT section does not apply to your device, a documented written rationale must be provided. Leaving sections blank without explanation will result in a request for clarification.

06
Documents unsigned or undated

All certificates and reports must carry the signature and date of the person issuing them. Unsigned documents are invalid and will be rejected at the first review stage.

How We Can Help

Documentation Support from TT Medical

Preparing a complete and compliant MDA submission requires both regulatory knowledge and careful attention to detail. TT Medical supports manufacturers at every stage of documentation preparation — from confirming classification and drafting the intended use statement, to reviewing the full CSDT before it goes to the CAB. Learn more about our experience or explore our full range of services.

CSDT preparation and review
ERSP checklist completion and cross-referencing
Local Authorised Representative (LAR) services
CAB coordination and submission management
End-to-end MDA registration management
Summary

Final Thoughts

A complete and well-prepared documentation package is the single most reliable way to avoid delays during MDA review. The MDA does not approve devices — it approves submissions. If the submission is incomplete, inconsistent, or incorrectly structured, the timeline resets regardless of how good the device actually is.

Use this checklist as your starting point. Have your documentation reviewed by an experienced regulatory consultant before it goes to the CAB. And if you're unsure which documents apply to your specific device class, speak to our consultancy team before you begin.

FAQ

Frequently Asked Questions

No. The CSDT is required for Class B, C, and D devices only. Class A devices do not require a full CSDT but must still submit core administrative and technical documents directly to MDA via MeDC@St.
ISO 13485 is primarily required for Class B, C, and D devices. For standard Class A devices it is not always mandatory, though the establishment licence holder must meet MDA quality system requirements. Class A sterile and measuring devices have additional requirements — confirm what applies to your device with your LAR.
Yes — through the Verification Route. If your device holds current approval from a recognised competent authority (EU CE, US FDA, Singapore HSA, TGA Australia, or Health Canada), the CAB can rely on that prior assessment and significantly reduce the assessment timeline. The same core documents are still required.
Expired certificates — ISO 13485, CAB reports, or reference agency approvals — will be flagged by the CAB or MDA. You will need to provide renewed versions before the submission can proceed, which adds time and cost. Always verify all certificate validity dates before submitting.
MDA targets 30 working days for Class A and 60 working days for Class B, C, and D after submission via MeDC@St. This begins after CAB assessment is complete for higher-class devices. Incomplete or inconsistent documentation can extend this timeline significantly.
Yes. TT Medical provides end-to-end documentation support — from drafting the intended use statement and completing the ERSP checklist, to reviewing the full CSDT before it goes to the CAB. We also act as your Local Authorised Representative and manage the MDA submission. Contact our team to get started.

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