I started my career in the pharmaceutical industry and spent several years there before making the switch, about ten years ago, to the MedTech and software as a medical device field.
That dual perspective has led me to a clear conclusion: the most useful AI compliance roadmap already exists, and MedTech wrote it.
With over 1,000 FDA-authorized AI/ML devices in use and established, repeatable regulatory pathways, the medical device industry has demonstrated that AI can be trusted in life-critical, patient-facing applications. These pathways enable not only initial deployment, but also ongoing scaling and adoption.
In this blog, we explore what pharma can learn from MedTech's approach to AI validation and how to apply it in a GxP context.
The Shift Pharma Needs to Make
One of the biggest differences I've seen between pharma and MedTech is how we approach validation.
MedTech forced us to solve a problem that pharma is only now confronting: how do you validate a system whose behaviour is shaped by data rather than deterministic code?
The answer lies in a fundamental conceptual shift. Traditional software validation asks whether the system works as specified. In MedTech, we added a second question: does the system support the right decisions in real-world conditions?
That shift, from product validation to decision-impact validation, is exactly what pharma needs to adopt.
In practice, I often see the same distinction emerge:
- Verification asks "did we build it right?" and focuses on performance, robustness, bias, and cybersecurity.
- Validation asks "did we build the right thing?" and ensures the AI system is fit for its intended GxP decision-support role, often including human-in-the-loop oversight.
In pharma terms, verification aligns with installation and functional testing, while validation aligns with fitness for intended use or user acceptance testing. The concepts themselves are not new, but their application to AI is.
Regulation as an Enabler, Not a Brake
Regulation is often perceived as a barrier, but frameworks such as GxP, GAMP, ISPE, and the EU AI Act provide something essential: clarity.
They require organizations to define:
- Intended use
- Acceptable risk
- Data governance
- Human oversight
- Monitoring
- Traceability
In doing so, they transform experimentation into trustworthy, scalable systems and provide guardrails for AI design.
In MedTech, Notified Bodies already expect additional controls around data governance and AI when it is part of a medical device.
At the same time, a broader standards ecosystem is maturing. ISO/IEC 42001, GAMP 5, Annex 22, and the ISPE AI maturity model are converging into a framework that pharma can adopt rather than build from scratch.
Start with What Is Proven
If I would give one practical recommendation, it would be this: start with what is already proven to work. A pragmatic starting point for pharma is to begin with static, deterministic AI models under human oversight.
These models offer:
- Predictability
- Control
- Straightforward GMP compliance
At the same time, they help build internal trust and maturity, paving the way for more advanced AI systems.
This mirrors MedTech, where static models remain the standard for the most critical applications.
And importantly, organizations do not have to tackle this alone. By combining QbD Group's compliance and validation expertise with delaware's digital and implementation capabilities, both the regulatory and technical dimensions can be addressed from the outset.
Looking to Go Deeper?
Understanding AI validation in a GxP context requires both regulatory insight and practical implementation guidance.
Watch the on-demand webinar on AI in Life Sciences to explore real-world examples and practical frameworks.
Watch the Webinar: AI in Life Sciences
Discover how to deploy AI in a trustworthy, validated, and inspection-ready way under GxP — covering data governance, explainability, and lifecycle management.
Watch the webinar关于作者
Project Manager at QbD Group
Pieter is a Project Manager at QbD Group, coordinating multi-disciplinary teams to deliver quality and regulatory consulting projects.
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