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Device Software Function: FDA’s 2025 AI Draft Definition

  • Writer: bengeelim
    bengeelim
  • 5 days ago
  • 3 min read

TL;DR — What’s a Device Software Function (DSF)?


A device software function (DSF) is stand-alone software that meets the FDA’s definition of a medical device.


In the 2025 AI draft guidance, FDA states:

“For purposes of this guidance, a device software function is a software function that meets the definition of a device under section 201(h) of the FD&C Act.” (lines 148–151, Jan 2025 draft)

If your code diagnoses, treats, predicts, or guides clinical decisions—and it runs independently—it almost certainly qualifies as a DSF and falls under FDA oversight.


device software function



Why This Term Matters for AI Teams?


SaMD has been the headline for years, but the AI draft guidance shifts focus to the function-level unit FDA regulates.


Knowing whether each function in your app is a DSF:


  • determines if you need a 510(k), De Novo, or PMA,

  • dictates whether you must submit a Predetermined Change Control Plan (PCCP), and

  • shapes your evidence package (validation, cybersecurity, data lineage).


Shortcut: If any code block influences a diagnosis or therapy decision, treat it as a DSF first—justify exclusions later.




 The Legal Definition Behind The Term



FD&C Act § 201(h)


A device is “any product… intended for use in diagnosis… cure, mitigation, treatment, or prevention of disease… which does not achieve its primary intended purposes through chemical action or being metabolized.”


Draft guidance (2025) clarification


FDA simply applies that device definition to software functions: intent-driven, not platform-driven. Your hosting environment (phone, cloud, on-prem) is irrelevant; the intended use is everything.



Function vs Feature vs Device Software

Term

Plain-English meaning

Reg status

Software feature

Capability inside an app (“zoom”, “export PDF”)

Usually unregulated

Software function

Discrete intended use (“flag likely tumour”)

May be regulated

Device software

Software that as a whole meets device definition

Regulated

Device software function (DSF)

The individual function within that software that triggers FDA oversight

Regulated & focal point of 2025 AI draft

Example: A mobile app has five features; only one analyses ECG to detect AFib. That one feature is the DSF.





Real-world AI DSF examples


Still unsure? Let’s look at a few real-world examples.

examples of AI device software functions

Imaging Classifier

An AI tool that flags potential tumors in MRI scans.

✅ Intended for diagnosis

✅ Used by clinicians

✅ Device software function


Insulin-Dosing Algorithm

Software that calculates recommended insulin doses using patient data.

✅ Directly affects treatment

✅ Regulated as a Class II or III DSF


Clinical Decision Support Flag

An app that highlights abnormal EKG patterns.

☑️ May qualify as DSF if it interprets or guides care—not just displays data





3-Question Litmus Test: Is Your Code a DSF?


Before worrying about submissions, start here.


  1. What is the intended use?

    If it diagnoses, treats, monitors, or predicts health conditions—watch out. FDA cares about intent, not disclaimers.


  2. Who is the end user?

    If it informs decisions by clinicians or patients, you’re probably in DSF territory.


  3. Is it standalone or embedded?

    Standalone software is a prime DSF candidate. If it’s embedded in a device’s firmware, it might fall under that device’s classification instead.





Why This Matters for Submissions


So your software qualifies as a DSF—now what?


PCCP Requirements


If your algorithm changes over time (think retraining, updating thresholds), the FDA now expects a Predetermined Change Control Plan. That means documenting:


  • What you’ll change in the future

  • How you’ll validate those changes

  • How risks will be mitigated


Other Supporting Documents


You’ll also need:


  • DSF description

  • Intended use statement

  • Model architecture diagram & training data lineage

  • Input/output data types

  • Performance claims and validation methods

  • Cybersecurity & SBOM per 2024 guidance


Skipping this will lead to delays—or worse, rejection.





FAQs


Q: Is firmware considered a Device Software Function?

Not typically. Firmware is usually considered part of the hardware device itself. DSFs are usually standalone or app-based.


Q: Do wellness algorithms count as DSFs?

Only if they make medical claims. If it just tracks steps or sleep, you’re probably safe. But once it says “reduce anxiety” or “improve glucose,” you may cross the line.


Q: How does PCCP tie into DSFs?

If your DSF includes AI/ML that evolves over time, the FDA expects a PCCP showing how you’ll manage those changes safely.

 
 

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