Regulatory Alignment Map

Built to regulator standards from day one.

Rosenbound is structured around the regulatory frameworks that govern its buyers: 21 CFR § 3060 for the 2026 PV ship, 21 CFR Part 11 ALCOA+ for the audit ledger, the FDA RWE Framework + PRINCIPLED for the methodology, the FDA 7-step AI credibility framework for documentation, the EU AI Act for European deployment, and the 510(k) + PCCP pathway for the post-2027 physician SaMD.

2026 ship pathway

FDA-compliant by design without a 510(k).

21st Century Cures Act § 3060 (Non-Device CDS Exemption)

FD&C Act § 520(o)(1)(E) · Effective Dec 13, 2016

The pharmacovigilance triage product satisfies all four exemption criteria: (i) for a healthcare professional, (ii) advisory/supporting not directing a clinical decision, (iii) intended to enable the professional to independently review the basis for the recommendation, (iv) supported by appropriate references. No 510(k) required for ship in 2026.

How Rosenbound qualifies: the Γ-bound + per-method drill-down + reproducibility certificate + methodology PDF provide everything a clinician needs for "independent review of the basis." Honest-interpretation captions on every estimate make explicit which population a metric refers to. FDA's own CDS guidance applies the IMDRF risk framework — we explicitly frame our PV product as "supporting human review of signal evidence" rather than "analyzing/interpreting a clinical test."

21 CFR Part 11 ALCOA+ Audit Ledger

21 CFR Part 11 § 11.10(a)–(k) · Electronic Records and Signatures

The audit module satisfies the eleven sub-requirements of § 11.10 (validation of systems, accurate copies, record retention, system-access controls, audit trail, sequence-of-events, authority checks, etc.) by architectural design rather than operator configuration.

How Rosenbound qualifies: SHA-256 chained ledger entries with monotonic_ns timestamps; fsync + PID-lock multi-writer protection; external-verifiable. The chain is queryable read-only by pharma audit teams and embeddable in their own regulated workflows without bolt-on audit infrastructure. ALCOA+ (Attributable, Legible, Contemporaneous, Original, Accurate, Complete, Consistent, Enduring, Available) addressed at the data-model level.
RWE methodology alignment

Aligned with what FDA + EMA are now asking for in observational submissions.

FDA Real-World Evidence Framework

"Considerations for the Use of Real-World Data and Real-World Evidence to Support Regulatory Decision-Making for Drug and Biological Products" · Final Aug 31, 2023

The flagship FDA RWE guidance directly motivates the five-method pentagon + Rosenbaum-Γ sensitivity bound as the right shape for an observational submission. Data-quality, transparency, and provenance expectations map onto the Cohort DSL + Cognitive Validation Report + reproducibility certificate.

How Rosenbound qualifies: every study generates the methodology + provenance + sensitivity artifacts the framework calls for, as default output rather than reviewer-requested follow-up.

EHR / Medical Claims Data Guidance

"Real-World Data: Assessing Electronic Health Records and Medical Claims Data" · Final Jul 25, 2024

Data-quality, traceability, and provenance expectations from this guidance map directly onto the Cohort DSL, the Cognitive Validation Report (which blocks ingestion of incoherent data), the cohort + data hash on every study, and the hash-chained audit ledger.

How Rosenbound qualifies: the Cognitive Validation Report's veto categories (temporal, ontological, biological, causal-acyclicity) operationalize the data-quality expectations into refuse-to-compute gates rather than warning labels.

Non-Interventional Studies Draft Guidance

"Non-Interventional Studies" · Draft Mar 21, 2024

States explicitly: "Identifying and addressing the presence of confounding and other forms of bias is critical… planned sensitivity analyses to assess the robustness of study findings." Calls for "assessment of unmeasured confounding factors."

How Rosenbound qualifies: the Rosenbaum-Γ bound IS the quantitative answer to this expectation. Reported on every estimate, not as a footnote.

PRINCIPLED Process (FDA Sentinel Innovation Center)

Desai, Wang et al. (Feb 12, 2024). BMJ, 384:e076460.

Prescribes "a plan for robustness assessments including deterministic sensitivity analyses, quantitative bias analyses, and net bias evaluation." Rosenbound's sensitivity pentagon + Γ-bound is exactly this class of instrument.

How Rosenbound qualifies: the five-method pentagon delivers deterministic + quantitative bias assessment in one platform; the Γ-bound delivers the net bias evaluation. Reported as default output on every study, not as appendix material.

TARGET Reporting Statement (target-trial emulation)

Cashin, Hansford, Hernán et al. JAMA 2025;334(12):1084–1093.

The TARGET reporting statement centers Hernán-style target-trial emulation for observational studies. Rosenbound's Studies module includes a target-trial protocol scaffold with explicit guards against immortal-time bias.

How Rosenbound qualifies: the Studies protocol-type scaffolding directly implements the TARGET checklist items (eligibility, treatment strategies, assignment, time-zero, outcome, causal contrast, analysis plan) as required form fields.

EMA Reflection Paper on RWE

EMA/CHMP/150527/2024 · Public consultation May–Aug 2024

Names "bias, confounding, data quality" as central concerns. DARWIN EU (>140 studies/year from 2025) is EMA's primary RWE pathway.

How Rosenbound qualifies: aligned messaging for European pharma partners. OMOP CDM v5.4 ingestion (roadmap) opens the DARWIN EU data-partner application path through Erasmus MC.
FDA AI credibility framework

Structured around the 7-step framework for AI/ML in drug submissions.

7-step AI/ML credibility framework

"Considerations for the Use of Artificial Intelligence To Support Regulatory Decision-Making for Drug and Biological Products" · Draft Jan 2025

Seven steps: (1) define the question of interest → (2) define the context of use (COU) → (3) assess model risk → (4) credibility-assessment plan → (5) execute → (6) document → (7) adequacy determination. Critically, this applies to the drug/biologic (pharma/RWE) path, not only devices — we structure documentation around COU and model risk for the PV and RWE products today, not for a future SaMD.

How Rosenbound qualifies: every study artifact includes the COU statement, model-risk classification, and credibility-assessment-plan references. Methodology PDF export is formatted to the 7-step framework for direct inclusion in submissions.

TRIPOD+AI Reporting Checklist

Collins, Moons et al. BMJ 2024. 27-item checklist superseding 2015 TRIPOD.

Auto-generated TRIPOD+AI-aligned model card on every Study — intended use, training data provenance, performance metrics, calibration, fairness assessment, model maintenance plan.

How Rosenbound qualifies: model card generator output aligned to all 27 items. Pharma authors copy the TRIPOD+AI card into their manuscripts directly rather than reconstructing it.
Post-2027 SaMD pathway

510(k) with PCCP, staged via FDA Q-Submission.

Predetermined Change Control Plan (PCCP)

"Marketing Submission Recommendations for a Predetermined Change Control Plan for Artificial Intelligence-Enabled Device Software Functions" · Final Dec 4, 2024

PCCP has three components: Description of Modifications, Modification Protocol, Impact Assessment. Available for 510(k), De Novo, and PMA pathways.

How Rosenbound qualifies: the no-LLM-in-the-prediction-path frozen-feature architecture is a genuine PCCP asset — it makes the modification space bounded and auditable, which is exactly what the final guidance rewards. PCCP draft scheduled Q4 2027 in parallel with the 510(k) submission.

Q-Submission Program (Pre-Sub)

FDA CDRH Q-Submission Program · ongoing pathway

Pre-Submission to discuss substantial-equivalence claim with FDA reviewers ahead of formal 510(k) filing. Identifies the predicate device, refines the intended-use statement, and de-risks the clinical-validation requirements.

How Rosenbound qualifies: Q-Sub filing planned ~12–18 months before the intended 510(k) submission. Pre-Sub scheduled post-first-signed pharma design partner; initial scope likely ICU anticoagulant choice given the W12 + W13 benchmark depth.

Breakthrough Device Designation (eligibility)

FDA Breakthrough Device Program

Per FDA's program page (Dec 31, 2025), CDRH/CBER have granted 1,246 Breakthrough Device designations with only 185 Marketing Authorizations. A 2024 JAMA Internal Medicine analysis found only 12.2% of designated devices (127 of 1,041) reached authorization — modest 510(k) acceleration.

How Rosenbound qualifies: potentially eligible for the W12 anticoagulation lane given quantitative advantage over existing point-estimate-based CDS. We pursue Breakthrough Designation ONLY if the indication is life-threatening AND credible clinical-benefit evidence exists — not as a marketing label.
EU AI Act (Europe-specific)

Gates EU deployments only. PV and RWE products are largely outside device scope.

EU AI Act Phased Application

Regulation (EU) 2024/1689 · Phased dates 2025–2027

AI used for diagnosis, CDS, triage, or patient monitoring is high-risk. Phased dates: prohibitions + AI-literacy applied Feb 2025; GPAI rules Aug 2025; most high-risk obligations Aug 2, 2026; Article 6(1) (AI embedded in CE-marked MDR/IVDR devices) applies Aug 2, 2027. The November 2025/February 2026 Digital Omnibus proposal may push standalone high-risk to Dec 2, 2027 and product-embedded to Aug 2, 2028 — monitor but do not rely on the delay.

How Rosenbound qualifies: the 2026 PV (non-device CDS) and RWE-methodology products are outside device scope; only the post-2027 physician-SaMD EU deployment triggers the full high-risk regime. AI Act gap analysis planned Phase 3 (2027). ISO 13485-style QMS extended with data-governance SOP, model-lifecycle procedure, bias-monitoring protocol, AI-specific complaint handling.

Watch the product walkthrough at rosenbound.ai — three moments that define the platform: the Cognitive Validation Report refusing incoherent data, the live Γ-bound sensitivity visualization, and the reproducibility certificate generated on every study. The full platform stays gated for Founding Partners.

Watch the preview →

pip install rosenbound  —  Official Python SDK for programmatic access: cohort upload, sensitivity-bounded study runs, and reproducibility certificate retrieval. Apache 2.0; Pydantic v2 typed; py.typed for IDE autocomplete + mypy. Platform access gated by Bearer token + RBAC + tenant scoping — the SDK is open, the audit substrate is not.

View on PyPI →

Pharma vendor security review — pre-prepared.

The Founding Partner Program includes a vendor-security packet (BAA, DPA, MSA templates, one-page security overview, SOC 2 Type I status, pen-test result) pre-prepared and ready for legal review. Designed to fast-track the vendor-onboarding process that typically stalls pharma deals for 4–8 weeks.