Clinical investigations and performance studies
Under the law, the manufacturer of a medical device shall submit to the Icelandic Medicines Agency (IMA) an application for a clinical investigation of a medical device and an application for a performance study of an in vitro diagnostic medical device.
IMA supervises that studies are conducted in accordance with the rules of good practice and legislation on patients' rights, including provisions on research and assessment by the National Bioethics Committee (Vísindasiðanefnd). IMA may halt a study if its conditions are not complied with.
Clinical investigations and performance studies are conducted to confirm that the general safety and performance requirements are met under normal conditions of the intended use of the device. In addition, undesirable side-effects are assessed for medical devices, and performance characteristics for in vitro diagnostic medical devices, together with an assessment of whether the benefit-risk ratio is acceptable.
By definition, clinical investigations are any systematic investigations involving one or more human subjects, undertaken to assess the safety or performance of a medical device. Provisions on clinical investigations and performance studies can be found in Chapter VI of Regulation (EU) 2017/745 on medical devices (MDR) and Regulation (EU) 2017/746 on in vitro diagnostic medical devices (IVDR). The parties concerned shall familiarise themselves carefully with these provisions.
The international standard ISO 14155:2026 "Clinical investigation of medical devices for human subjects – Good clinical practice" can be used when conducting studies. The guidance from the European Commission can also be used.
Notification obligation
The obligation to notify investigations or studies under the provisions of the regulations depends on whether the medical device already bears the CE marking and on the purpose of the investigation or study. An authorisation must be sought from the National Bioethics Committee for investigations and studies of medical devices, in accordance with the Committee's detailed guidance.
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When must an application be submitted?
An application must be submitted to IMA if a performance study:
Involves surgically invasive sample-taking performed solely for the purpose of the performance study.
Is an interventional clinical performance study, where the test results may influence patient management decisions and/or be used to guide treatment.
Involves additional invasive procedures or other risks for the subjects of the study, even if those risks are not related to the sample-taking itself.
Involves companion diagnostics and does not use only left-over samples.
Notification obligation
The obligation to notify investigations or studies under the provisions of the regulations depends on whether the medical device already bears the CE marking and on the purpose of the investigation or study. An authorisation must be sought from the National Bioethics Committee (Vísindasiðanefnd) for investigations and studies of medical devices, in accordance with the Committee's detailed guidance.
Contentful
Content missing or inaccessible
When must an application be submitted?
An application must be submitted to IMA if a performance study:
Involves surgically invasive sample-taking performed solely for the purpose of the performance study.
Is an interventional clinical performance study, where the test results may influence patient management decisions and/or be used to guide treatment.
Involves additional invasive procedures or other risks for the subjects of the study, even if those risks are not related to the sample-taking itself.
Involves companion diagnostics and does not use only left-over samples.
When must a notification be submitted?
A notification must be submitted to IMA if a performance study:
Concerns a companion diagnostic using only left-over samples, cf. Article 58(2) of the IVDR.
Evaluates a CE-marked device within its intended purpose and involves additional procedures for the subjects that are invasive or burdensome, cf. Article 70(1) of the IVDR.
The image below is from the Medical Device Coordination Group (MDCG) guidance document "MDCG 2025-5 Questions and Answers regarding performance studies of in vitro diagnostic medical devices under regulation (EU) 2017/746"
If there is any doubt as to whether a particular investigation or study must be notified to IMA, you can contact IMA and request further information.
Applications
Applications for clinical investigations and performance studies shall be submitted to IMA via the Contact us portal, after which IMA will request the relevant documents. Once the implementation of EUDAMED has been fully completed, applications for clinical investigations and performance studies will move entirely to EUDAMED. A fee is charged in accordance with IMA's tariff of fees.
Report submission
End of an investigation or study as planned
IMA shall be notified of the end of a clinical investigation no later than 15 days after the investigation ends.
After the investigation ends, a final report shall be submitted to IMA as soon as possible and no later than 12 months after the end of the investigation. The final report shall contain a critical evaluation of all data collected during the investigation.
Investigation or study terminated early or temporarily halted
If a clinical investigation or study has to be terminated early, or an investigation/study is temporarily halted, IMA shall be notified within 15 days and the reason for the termination or halt shall be explained.
If an investigation is halted or terminated for safety reasons, this shall be notified within 24 hours.
If an investigation is terminated early, the final report shall be submitted as soon as possible and no later than 3 months after the termination of the investigation.
The final report shall contain a critical evaluation of all data collected up to the end of the investigation.
Further guidance on preparing the final report can be found in Guidance on the publication of the clinical investigation reports and their summaries in the absence of EUDAMED. Otherwise, refer to Article 77 of the MDR and Article 73 of the IVDR, as applicable.
Timelines
Time-bound procedure | Maximum number of days |
Time to validate an application for a clinical investigation or study after IMA's confirmation of receipt | 10 - 15 |
IMA considers the application incomplete or outside the scope of the regulations. Time the applicant is entitled to comment or complete the application. | 10 - 35 |
Time to validate the application after additional documents or comments are received by IMA | 5 – 10 |
Time to assess an application where IMA's authorisation is required | 45 |
Time to assess an application where IMA's authorisation is required and consultation with experts is needed | 65 |
Time to assess modifications to a previously authorised clinical investigation or study | 38 |
Time to assess modifications to a previously authorised clinical investigation or study that require consultation with experts | 45 |
Time to notify that a clinical investigation or study has ended | 15 |
Time to notify that an investigation or study has been halted for safety reasons | 1 |
Time to submit the final report after an investigation or study was terminated early | 90 |
Time to submit the final report after an investigation or study was completed as planned | 365 |
Further information on the different procedures for clinical investigations and on when IMA's authorisation must be obtained before an investigation begins can be found in Article 70 of the MDR.
