S&E Checklist & Compliance Matrix
Use this checklist when preparing a Device Licence application to ensure Schedule 1 Safety and Effectiveness Requirements are addressed systematically.
How to use this checklist
For each requirement:
- Determine whether the requirement applies to your device
- Identify how compliance is demonstrated (standard, test report, risk analysis, etc.)
- Reference the specific document in your technical file
Schedule 1 compliance matrix
| Requirement | Applicable? | How demonstrated | Key standards |
|---|---|---|---|
| Risk minimisation (benefit-risk balance) | All devices | Risk management file | ISO 14971 |
| Performance over lifetime | All devices | Durability testing, shelf-life data | ISO 11607 (packaging) |
| Biocompatibility | Devices with patient contact | Biocompatibility evaluation report | ISO 10993 series |
| Sterility | Sterile devices | Sterilisation validation | ISO 11135 / 11137 / 17665 |
| Electrical safety | Active devices | Electrical safety test report | IEC 60601 series |
| EMC/EMI | Active devices | EMC test report | IEC 60601-1-2 |
| Software | Devices with software | Software lifecycle documentation | IEC 62304 |
| Usability | All devices | Usability engineering file | IEC 62366-1 |
| Measuring function | Devices with measurement | Accuracy/precision testing | Relevant metrology standards |
| Radiation protection | Radiation-emitting devices | Radiation safety testing | REDA, applicable standards |
| Labelling | All devices | Review of label vs. Schedule 1 requirements | MDR s. 21–26 |
| IFU | All devices (where applicable) | Draft IFU reviewed against requirements | MDR s. 21–26 |
Device-specific requirements
Implantable devices
Additional requirements apply to implantable devices, including:
- Long-term biocompatibility
- Implant card requirements (for certain implantable devices)
- Special labelling (MRI safety information)
See Implantable Devices.
IVDs
IVD devices have specific performance requirements (analytical and clinical performance). See IVD Medical Devices.
SaMD
Software-only devices require particular attention to IEC 62304 documentation and cybersecurity. See Software as a Medical Device.
Including the compliance matrix in your submission
Health Canada expects Device Licence submissions to include either:
- A Safety and Effectiveness Summary that maps claims to evidence for each applicable Schedule 1 requirement, or
- A Standards Attestation for applicable Mandatory Standards, plus supporting test reports or certificates of conformity
Organise your compliance evidence in a Technical File that mirrors the structure of Schedule 1. This makes Health Canada's review more efficient and reduces the likelihood of clarification requests.
Legislative source: Medical Devices Regulations, SOR/98-282, Schedule 1; s 32 (contents of Device Licence application)
For any Schedule 1 requirement marked as 'Not applicable,' provide a brief justification in your Safety and Effectiveness Summary. For example: 'Sterility — Not applicable: device is supplied non-sterile for single use only.' This demonstrates systematic consideration of all requirements rather than oversight.
The tip at the bottom addresses this partially, but should be expanded to its own section: 'Non-applicable requirements — For each Schedule 1 requirement, you must make an explicit determination of applicability. Document your rationale in the Safety and Effectiveness Summary. Examples include: "Sterility — Not applicable: device is supplied non-sterile for single-use only" or "Electrical safety — Not applicable: device is non-electric and contains no electronic components." This demonstrates systematic consideration of all requirements and reduces reviewer clarification requests.'