What changed on 1 March 2026 — and why it matters for your SaMD
The Singapore–Malaysia medical device regulatory reliance programme began as a six-month pilot on 1 September 2025. On 1 March 2026, following the pilot's successful completion, Malaysia's Medical Device Authority (MDA) officially confirmed that the programme will continue permanently. This is not an extension — it is full implementation.
Under this programme, SaMD manufacturers whose devices are registered in the Singapore Medical Device Register (SMDR) can apply for Malaysian registration through the Verification Route — a significantly accelerated pathway compared to standard registration. Review time at the Conformity Assessment Body (CAB) drops from 60 working days under full assessment to 30 working days. Final MDA registration follows within another 30 working days. Total timeline: approximately 60 working days versus the standard 120+ days.
The EU MDR → Singapore → Malaysia pathway: step by step
Step 1: EU MDR CE marking as your foundation
Singapore HSA accepts EU MDR CE marking as a reference approval in its evaluation process. This means your MDR technical documentation, clinical evaluation, and QMS serve as the primary evidence base for HSA registration — reducing the documentation burden significantly compared to companies without prior international approvals.
HSA's GL-04 Rev.4 (December 2025) aligns software documentation requirements with IEC 62304, ISO 14971:2019, and MDCG-equivalent guidance. If you have built your technical file to MDR Annex II/III standards, the majority of what HSA needs is already produced. Key additions include HSA-specific cybersecurity documentation, post-market surveillance procedures aligned with HSA's change management programme, and Singapore-specific labelling and IFU requirements.
Step 2: Singapore HSA registration via SHARE platform
Submit your product registration application through HSA's SHARE (Submission of Health Product Application for Registration & Evaluation) online system. Your Singapore-based Product Registrant (a licensed importer or distributor) must hold the registration on your behalf unless you are yourself a licensed importer in Singapore.
Classification under HSA follows a Class A–D framework. Most clinical SaMD falls into Class B or C. Class B devices target 120–180 day review timelines for complete submissions; Class C typically 180–270 days. EU MDR reference approval accelerates this in practice.
Once registered, your device is listed on the Singapore Medical Device Register (SMDR). This SMDR listing is the key that unlocks the Malaysian Verification Route.
Step 3: Malaysia MDA registration via Verification Route
With your SMDR listing, your Malaysian Authorised Representative (AR) submits to a licensed Malaysian Conformity Assessment Body (CAB) using the Verification Route, as outlined in MDA guidance document MDA/GD/0070. The CAB reviews your application within 30 working days — relying on HSA's prior regulatory assessment rather than conducting a full independent review. The CAB certificate then supports your MDA registration application, completed within a further 30 working days.
Your Malaysian AR must hold a valid Establishment Licence and Good Distribution Practice for Medical Devices (GDPMD) certificate. For Class B, C, and D devices — which is where most SaMD sits — the AR submits through MDA's MeDC@St online system with the SMDR certificate, CSDT dossier, and CAB certificate as the primary documents.
What HSA requires beyond EU MDR documentation
Your EU MDR technical file covers the majority of what HSA needs, but several additions are required for Singapore submission:
- HSA-format Declaration of Conformity: HSA requires a Declaration of Conformity in the format specified in HSA's guidance, in addition to (or replacing) your EU MDR DoC. The content is similar, but the format and references to Singapore legislation are specific.
- Singapore-specific labelling: Labels must reference the Singapore product registration number once issued. English is the primary language for professional-use SaMD — no Malay translation is required for SaMD in Singapore, unlike for consumer-facing home-use devices.
- Updated cybersecurity documentation: HSA's December 2025 GL-04 update strengthened cybersecurity requirements, including operating system end-of-life management plans. If your cybersecurity documentation was written before December 2025, update it to address OS end-of-life explicitly.
- ASEAN Common Submission Dossier Template (CSDT): HSA uses the ASEAN CSDT format for submission. Your EU MDR Annex II documentation maps closely to this format, but the CSDT has specific section headings and ordering that your submission must follow.
- Post-market obligations and change notification: Singapore has a defined Change Management Programme (CMP) for SaMD. For AI/ML SaMD, the December 2025 update expanded CMP scope. You need a Singapore-specific PMS and change notification procedure in your QMS.
The Malaysia layer: what MDA adds beyond HSA requirements
Under the Verification Route, Malaysia does not conduct a full independent technical review — it relies on HSA's assessment. However, several Malaysia-specific requirements still apply:
- Malaysian Authorised Representative: You must appoint a licensed AR in Malaysia who holds an Establishment Licence and GDPMD certificate. This is a mandatory prerequisite — unlike Singapore where a Product Registrant may serve this role.
- Malaysia-specific labelling: Labels must include the MDA product certificate number once issued. For home-use devices, Bahasa Malaysia translation is mandatory — for professional SaMD, English is generally sufficient.
- Declaration of Conformity in MDA format: Appendix 1A of the Medical Device Regulation 2012 specifies the Malaysian DoC format. This is in addition to your Singapore and EU MDR declarations.
- GDPMD compliance of your AR: Your Malaysian AR's own compliance status directly affects your registration — verify their GDPMD certificate is current before submitting.
Singapore as a gateway beyond Malaysia
The HSA–MDA reliance programme is part of a broader ASEAN regulatory convergence trend that extends beyond just two markets. Singapore HSA approvals are increasingly recognised as reference approvals across the region. As of 2026, Singapore registration supports or accelerates entry into:
- Malaysia: Full Verification Route — permanent from March 2026 (as covered in this guide)
- Philippines FDA: Singapore approvals are accepted as reference in the Philippines' streamlined pathway for internationally-approved devices
- Thailand FDA: Thailand-Malaysia reliance pilot (February–April 2026) expands the reliance network — Singapore approvals accepted by MDA, which has a reliance agreement with Thailand
- Hong Kong: Singapore approvals support applications to MDACS (Medical Device Administrative Control System)
- Vietnam: Expedited review pathway for SMDR-listed devices under Circular 05/2022
This means that a single Singapore registration — built on your EU MDR technical file — can efficiently support entry into 5–6 ASEAN markets. For SaMD companies with EU MDR certification planning Asian expansion, Singapore is not just one market: it is the regulatory hub for the region.
- ↗ HSA–MDA MOU and Regulatory Reliance Pilot launch — Singapore HSA
- ↗ HSA Regulatory Reliance — ongoing implementation — Singapore HSA
- ↗ MDA Malaysia — Medical Device Authority official portal — Malaysia MDA
- ↗ HSA GL-04 Rev.4 (Dec 2025) — SaMD lifecycle approach — Singapore HSA