Section 524B · FDA 2023 Final Guidance · Premarket Submissions

FDA is refusing submissions
without cybersecurity docs.

Ten document templates covering every cybersecurity requirement for FDA premarket submissions. Threat model, risk assessment, SBOM, CBOM, vulnerability management, patch management, CVD procedure, and more.

Instant download. For QA/RA teams at medical device manufacturers.

Section 524B is mandatory. FDA is refusing-to-file non-compliant submissions.

The Consolidated Appropriations Act 2023 (Section 524B) made cybersecurity documentation a legal requirement for all premarket device submissions after March 29, 2023. FDA issued its Final Guidance in September 2023.

FDA reviewers are now issuing Refuse to File (RTF) letters for submissions that lack required cybersecurity content — threat model, SBOM, security architecture, vulnerability management plan, and pre-submission checklist. Most QA teams are building these documents from scratch under active submission deadlines.

10 Documents. Complete FDA cybersecurity coverage.

From premarket submission through post-market monitoring.

Document 01

Cybersecurity Risk Assessment Template

FDA Guidance (Sept 2023) × ISO 14971 integration. Covers threat-based risk assessment, CVSS scoring, residual risk evaluation, and risk-benefit documentation. Mapped to Annex B of the FDA guidance and Section 524B of the Omnibus Act.

Document 02

Cybersecurity Threat Model Template

FDA 2023 Final Guidance Section 3.2 compliant. Structured STRIDE-based threat modeling for medical devices. Covers attack surface analysis, data flow diagrams, trust boundaries, and threat enumeration per FDA expectations.

Document 03

Software Bill of Materials (SBOM) Template

FDA Section 524B / Cybersecurity Guidance (Sept 2023) compliance template. Covers SBOM format requirements (SPDX/CycloneDX), component inventory, version tracking, known vulnerability mapping, and SBOM maintenance procedures.

Document 04

Security Architecture Description Template

FDA Cybersecurity Guidance Section 3.3 compliant. Documents security controls, authentication mechanisms, data encryption, network segmentation, secure communication protocols, and defense-in-depth architecture for premarket submissions.

Document 05

Vulnerability Management Plan

FDA Cybersecurity Guidance Section 5 post-market requirements. Ongoing vulnerability identification, triage, and remediation procedures. Covers CVE monitoring, severity classification, remediation timelines, and FDA reporting thresholds.

Document 06

Pre-Submission Cybersecurity Checklist

FDA 2023 Final Guidance compliance verification checklist. 100+ checkpoints mapped to Tier 1 and Tier 2 cybersecurity documentation requirements. Use as a pre-submission gate before filing with FDA.

Document 07

Patch Management Policy Template

End-to-end patch lifecycle for medical devices. Covers patch identification, risk assessment, testing, deployment, and post-deployment verification. Mapped to FDA Section 5 and IEC 62443 patch management requirements.

Document 08

Coordinated Vulnerability Disclosure Procedure

CVD policy per ISO 29147/30111 and CISA guidelines. Covers external researcher intake, internal triage, remediation coordination, disclosure timelines, and FDA reporting obligations for exploited vulnerabilities.

Document 09

Cybersecurity Bill of Materials (CBOM) Template

Comprehensive security inventory beyond SBOM. Covers cryptographic algorithms, security hardware components, network interfaces, authentication modules, and security-critical firmware. NIST SP 800-53 and FDA guidance aligned.

Document 10

Post-Market Cybersecurity Monitoring Plan

Ongoing security surveillance for fielded medical devices. Covers threat intelligence feeds, vulnerability scanning cadence, incident response triggers, field safety notice criteria, and FDA MDR/MedWatch reporting thresholds.

Why this works

🔐

Section 524B is law — not guidance

The Consolidated Appropriations Act 2023 made cybersecurity submissions mandatory for device submissions after March 29, 2023. FDA is now refusing to accept submissions that lack the required cybersecurity documentation.

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Built to FDA 2023 Final Guidance spec

These templates reflect the actual structure FDA reviewers expect: threat modeling, SBOM, security architecture, vulnerability management, and post-market monitoring — organized for premarket submission.

Stop building from scratch under deadline

FDA cybersecurity documentation takes months to build correctly. Start with the right structure, fill in your device-specific data, and submit with confidence. Regulatory architecture is already here.

Build your cybersecurity file before FDA refuses to accept your submission.

$10K–$30K
Cybersecurity consultant engagement
3–6 months
RTF letter and resubmission delay
$247
This toolkit

Stripe checkout. Instant download after payment.

Frequently asked

Does this apply to my 510(k) or De Novo submission?

Yes. Section 524B applies to all premarket submissions (510(k), De Novo, PMA, HDE) submitted after March 29, 2023. FDA is currently refusing to file submissions that lack the required cybersecurity content. The checklist (Document 06) maps every required element.

What is the difference between SBOM and CBOM?

An SBOM (Software Bill of Materials) inventories all software components — open source libraries, third-party modules, OS components. A CBOM (Cybersecurity Bill of Materials) goes further: it includes cryptographic algorithms, hardware security modules, authentication components, and all security-critical elements. FDA guidance references both. Templates 03 and 09 cover each.

Do I need all 10 documents for a basic 510(k)?

FDA distinguishes Tier 1 (higher cybersecurity risk) from Tier 2 (standard) submissions. Tier 2 requires: cybersecurity risk assessment, SBOM, security architecture documentation, vulnerability management plan, and the pre-submission checklist. All Tier 1 requirements plus threat model, CBOM, patch management, and CVD procedure. Document 06 maps which tier applies to your device.

Is this legal advice or regulatory consulting?

No. This is a practitioner reference toolkit built on the FDA 2023 Final Guidance and Section 524B requirements. Consult your regulatory counsel for formal compliance opinions and submission strategy.

FDA won't wait. Your cybersecurity file shouldn't either.

Ten documents. Start with the right structure. Fill in your device data. Submit with confidence.

Also: ISO 14971 Risk Management $247 · EU IVDR Starter Kit $197

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