Skip to main content

SaMD vs Embedded Medical Device Software: Which One Are You Building?

  • Published:
  • Time to read: 8 min read
Add as a preferred source on Google
SaMD vs Embedded Medical Device Software: Which One Are You Building?
A plain three question test to tell Software as a Medical Device from embedded device software, and what each path means for standards, team and budget.
Summarize with AI ChatGPT ClaudeClaude Perplexity Grok Gemini

What Is the Difference Between SaMD and Embedded Medical Device Software?

Software as a Medical Device (SaMD) performs a medical purpose on its own. Embedded medical device software runs inside a hardware device and exists to drive it. Which one you are building changes your regulatory path, your team and your budget.

Groovy Web builds software for regulated healthcare products from Nadiad, Gujarat. See our medical device software development work, or read how healthcare app compliance works first.

This guide gives you a plain test to classify your product, shows what changes after you decide, and lists the mistakes that cost founders months.

How Does the FDA Define Software as a Medical Device?

The FDA describes SaMD as software intended for one or more medical purposes that performs those purposes without being part of a hardware medical device. The FDA draws this wording from the International Medical Device Regulators Forum, as set out on its Software as a Medical Device page.

The same page separates SaMD from software that is integral to a medical device and from software used to make or maintain one. Only the first group, stand-alone software with a medical purpose, is SaMD.

What Counts as Embedded Medical Device Software?

Embedded software, also called firmware, is the code that runs a hardware device. The FDA's page of examples of Software as a Medical Device names two cases that are not SaMD: software that drives the motors and pumping in an infusion pump, and closed-loop control software in an implantable pacemaker.

Short on time? Get the SaMD vs embedded decision test in your inbox

One page with the three question test, the IEC 62304 safety classes and what to confirm before you hire a build team. We email you the PDF.

No spam. Unsubscribe anytime.

Industry shorthand for this group is Software in a Medical Device, or SiMD. It is a working label, not a separate legal category, so use it to talk with your team and rely on the FDA wording for filings.

Is My Product SaMD or Embedded? A Three Question Test

Ask these three questions in order. This is the screen we use in first calls, and it settles most products in minutes. It is a planning aid, not a regulatory ruling.

QuestionIf yesIf no
1. Does the software have a medical purpose, such as diagnosing, monitoring or treating?Go to question 2Likely not a device. Confirm with the FDA
2. Does it perform that purpose without being part of a hardware device?SaMDGo to question 3
3. Is its job to drive or control a hardware device?Embedded softwareRe-read the FDA examples with your regulatory lead
Decision flow: a medical purpose performed without a hardware device is SaMD, while software that drives a hardware device is embedded

The FDA states that medical software running on a general purpose computing platform, such as a phone or a consumer camera, is still SaMD. Where the code runs does not decide the class. What it is for does.

Which Medical Software Is Usually SaMD?

The FDA's own examples range from a smartphone app that displays MRI images for diagnosis to computer-aided detection software that helps find breast cancer. It also lists treatment planning software that feeds a linear accelerator.

Typical SaMD projects we are asked about include image analysis tools, clinical decision support, remote monitoring dashboards and digital therapeutics. Software that only encrypts or stores device data has no medical purpose of its own, and the FDA says it is not SaMD.

Not sure if your product is SaMD or embedded? Get a free scoping call

How Do the Build Paths Differ?

SaMDEmbedded software
Where it runsPhone, browser, cloud or serverMicrocontroller or board inside the device
Typical stackMobile, web, cloud, data and AIC or C++, real-time operating system, drivers
Release speedUpdates can ship often, with change controlTied to hardware revisions and field updates
Hardest partProving clinical performance and data securitySafety, timing and hardware integration
Team needsProduct, cloud, data and mobile engineersFirmware and electronics engineers

Many products are both. A glucose monitor has firmware in the sensor and an app that reads the data. Plan the two as separate software items with a defined interface, because each has its own risk and testing.

What Standards Apply to Either Path?

Both paths follow a documented software life cycle. IEC 62304 is the standard for medical device software life cycle processes. It sorts software into three safety classes, and the class sets how much documentation and testing you owe.

As explained in Greenlight Guru's guide to IEC 62304 software safety classes, Class A means a failure cannot cause injury, Class B means non-serious injury is possible, and Class C means death or serious injury is possible. Higher classes cost more to build.

Your manufacturer quality system matters too. The FDA's Quality Management System Regulation became effective on February 2, 2026 and incorporates ISO 13485:2016 by reference. Your engineering partner's records must fit inside that system.

Which Path Costs More and Takes Longer?

Neither is always the cheaper one. Cost follows the IEC 62304 safety class and the risk of harm far more than it follows SaMD or embedded. A Class A app can cost less than a Class C firmware module, and a Class C diagnostic app can cost more than both.

Embedded work adds hardware cycles and field update planning. SaMD adds clinical evidence, cybersecurity and data handling. Ask any vendor to price documentation and testing as separate lines, so the quote shows where the effort goes.

What Mistakes Do Teams Make When Classifying Their Software?

Three come up most. Teams treat a wellness app as unregulated when its claims are medical. They merge the firmware and the app into one plan. And they pick a development partner before they know their safety class.

FREE · 30 MINUTES · NO OBLIGATION

Get a free medical software scoping review

Tell us what your product does and who uses it. A senior engineer will help you check the software class and plan the build.

No sales pitchBuilt for teams comparing voice AI vendorsReply within 1 business day

Decide your intended use first, in one written sentence, because claims in your marketing and your labeling shape how the FDA sees the product. Then pick the class, then the partner, in that order.

Which Should You Build First?

Choose SaMD if: your value is in analysis, decision support or monitoring, and you can use hardware that already exists. You can reach users faster and update more often.

Choose embedded software if: your value depends on new hardware that senses, delivers or controls something. Budget for hardware cycles and a longer path to release.

Choose both, in stages, if: you need a device and an app. Start with the part that carries the most risk, and define the interface between the two before either team writes code.

Bottom line: classify first, then scope. If your software performs a medical purpose on its own, it is SaMD. If its job is to run a device, it is embedded. Confirm the class with a regulatory expert before you sign a build contract.

Frequently Asked Questions

What is SaMD in simple terms?

SaMD is software that does a medical job by itself, such as helping diagnose or monitor a condition, without being built into a hardware device. A mobile app that analyses a scan is a common example.

Is firmware in a medical device SaMD?

No. The FDA says software that drives or controls a hardware device, like an infusion pump or a pacemaker, is not SaMD. It is still regulated as part of the device and must follow a documented life cycle.

Is a mobile health app a medical device?

It depends on its intended use. If the app is meant to diagnose, treat or monitor a condition, it can be SaMD. A general wellness or record keeping app may not be. Confirm with the FDA if the claims are borderline.

Does IEC 62304 apply to SaMD?

Yes. IEC 62304 covers medical device software life cycle processes, and SaMD teams use it to structure planning, design, testing and maintenance. The safety class you assign decides how much evidence you need.

Can one product be both SaMD and embedded?

Yes. A connected device often has firmware inside and a companion app outside. Treat them as two software items with a documented interface, each with its own risk assessment and tests.

Can an India-based team build regulated medical software?

Yes, if the team works inside your quality system and keeps the records the standards require. Ask for sample documentation, named engineers and data location terms before you sign.


Not Sure Which Path Your Product Takes?

Groovy Web builds software for medical device teams and can help you scope the build once your safety class is clear. Tell us what the product does and we will tell you what to confirm before you start.

Request a Quote →


Related Services


Further Reading

Ship Production-Grade AI with Senior Engineers

Our AI-First engineering approach delivers production-ready applications in weeks, not months.

Hire an AI-First Engineering Team

Was this article helpful?

Groovy Web Team

Written by Groovy Web Team

Groovy Web is an AI-First development agency specializing in building production-grade AI applications, multi-agent systems, and enterprise solutions. We've helped 200+ clients ship production-grade software with senior engineers and AI Agent Teams.

Get Free Consultation
Start a Project

Got an Idea?
Let's Build It Together

Tell us about your project and we'll get back to you within 24 hours with a game plan.

Schedule a Call Book a Free Strategy Call
30 min, no commitment
Response Time

Mon-Fri, 8AM-12PM EST

4hr overlap with US Eastern
500+ Projects Delivered
18+ Years Experience
3 Global Offices

Follow Us

1-week risk-free trial, keep the code

Hire an AI-First Engineering Team
Production-Grade. Your US Hours.

For startups & product teams

One senior engineer, AI-accelerated. Owns architecture, security, and the last 20% AI tools leave broken. No recruitment, no ramp-up.

Trusted by 200+ startups worldwide

Production-grade delivery
4hr live US overlap
Start in 48 hours

No long-term commitment · 100% IP yours · Cancel anytime