• Login
    • Advanced search
    • Title
    • Channel
    • Module
  • Home
  • Client Solutions
    • Digital Transformation
    • Energy Transition
    • Supply Chains
    • Sustainability and ESG
    • Workforce Redesign
  • Sectors
    • Consumer Goods & Retail
    • Energy, Mining & Infrastructure
    • Financial Institutions
    • Healthcare & Life Sciences
    • Industrials, Manufacturing & Transportation
    • Technology
  • Learning Resources
    • Podcasts
    • Video Chats
    • Webinars
  • Area of Law
    • Antitrust & Competition
    • Artificial Intelligence
    • Banking & Finance
    • Capital Markets
    • Cybersecurity & Data Privacy
    • Data & Technology
    • Dispute Resolution
    • Employment & Compensation
    • Environment & Climate Change
    • Financial Services Regulatory
    • Inclusion, Diversity & Equity
    • Intellectual Property
    • International Commercial & Trade
    • Investigations, Compliance & Ethics
    • Mergers & Acquisitions
    • Pensions
    • Private Equity
    • Projects
    • Real Estate
    • Restructuring & Insolvency
    • Tax
  • Location
    • International

    • International
    • Asia Pacific

    • Australia
    • China
    • Hong Kong
    • Indonesia
    • Japan
    • Malaysia
    • South Korea (Korea, Republic of)
    • Singapore
    • Taipei
    • Thailand
    • Philippines
    • Vietnam
    • EMEA

    • Austria
    • Bahrain
    • Belgium
    • Czech Republic
    • Egypt
    • EU
    • France
    • Germany
    • Hungary
    • Italy
    • Kazakhstan
    • Luxembourg
    • Morocco
    • Netherlands
    • Poland
    • Portugal
    • Qatar
    • Russian Federation
    • Saudi Arabia
    • South Africa
    • Spain
    • Sweden
    • Switzerland
    • Türkiye
    • Ukraine
    • United Arab Emirates
    • United Kingdom
    • North America

    • Canada
    • United States
    • Latin America

    • Argentina
    • Brazil
    • Colombia
    • Chile
    • Mexico
    • Peru
    • Venezuela
Baker McKenzie InsightPlus Home
      • Title
      • Channel
      • Module
    • Hit ENTER to search in content
    • Advanced search
    • Login
  • Home
  • Client Solutions
    • Digital Transformation
    • Energy Transition
    • Supply Chains
    • Sustainability and ESG
    • Workforce Redesign
  • Sectors
    • Consumer Goods & Retail
    • Energy, Mining & Infrastructure
    • Financial Institutions
    • Healthcare & Life Sciences
    • Industrials, Manufacturing & Transportation
    • Technology
  • Learning Resources
    • Podcasts
    • Video Chats
    • Webinars
  • Area of Law
    • Antitrust & Competition
    • Artificial Intelligence
    • Banking & Finance
    • Capital Markets
    • Cybersecurity & Data Privacy
    • Data & Technology
    • Dispute Resolution
    • Employment & Compensation
    • Environment & Climate Change
    • Financial Services Regulatory
    • Inclusion, Diversity & Equity
    • Intellectual Property
    • International Commercial & Trade
    • Investigations, Compliance & Ethics
    • Mergers & Acquisitions
    • Pensions
    • Private Equity
    • Projects
    • Real Estate
    • Restructuring & Insolvency
    • Tax
  • Location
    • International

    • International
    • Asia Pacific

    • Australia
    • China
    • Hong Kong
    • Indonesia
    • Japan
    • Malaysia
    • South Korea (Korea, Republic of)
    • Singapore
    • Taipei
    • Thailand
    • Philippines
    • Vietnam
    • EMEA

    • Austria
    • Bahrain
    • Belgium
    • Czech Republic
    • Egypt
    • EU
    • France
    • Germany
    • Hungary
    • Italy
    • Kazakhstan
    • Luxembourg
    • Morocco
    • Netherlands
    • Poland
    • Portugal
    • Qatar
    • Russian Federation
    • Saudi Arabia
    • South Africa
    • Spain
    • Sweden
    • Switzerland
    • Türkiye
    • Ukraine
    • United Arab Emirates
    • United Kingdom
    • North America

    • Canada
    • United States
    • Latin America

    • Argentina
    • Brazil
    • Colombia
    • Chile
    • Mexico
    • Peru
    • Venezuela
  1. Healthcare & Life Sciences
  2. Singapore: HSA updates guidelines on risk classification of SaMD and qualification of CDSS

Singapore: HSA updates guidelines on risk classification of SaMD and qualification of CDSS

30 Jul 2025    2 minute read
    • Share by email
    • Share on
    • Twitter
    • LinkedIn
    • Facebook
    • Google plus
    • Get link
    • Get QR Code
    • Download
    • Print
Sectors Healthcare & Life Sciences

In brief

On 21 July 2025, the Health Sciences Authority (HSA) revised its guidelines on the risk classification of software as a medical device (SaMD) and the qualification of clinical decision support software (CDSS).

The revised guidelines incorporate changes to improve online searchability and international alignment on terminology, provide better clarity on the classification of SaMDs under Class B and include additional criterion to determine whether or not a CDSS is considered a medical device.


Contents

In more detail

The following are the notable changes to the guidelines:

  • Refinements to terminology: The title of the guidelines has been changed to “Guidelines on Risk Classification of SaMD and Qualification of Clinical Decision Support Software (CDSS)” to improve online searchability. For better international alignment, the term “Standalone Medical Mobile Applications” has been revised to “SaMD.”
  • Class B medical device criterion for SaMDs: HSA has clarified that SaMDs will be classified as Class B if they are intended to analyze, measure or monitor (i) a vital physiological process (e.g., heart rate, blood pressure, respiratory rate, body temperature) or (ii) anatomical structure images (e.g., X-rays of bones, ultrasound images of organs, intraoral images) in order to drive clinical/patient management. This clarification is in line with HSA’s guidance on the risk classification of general medical devices.
  • Clarification on CDSS qualification: HSA has provided clarification on when CDSS would not be regulated as a medical device, i.e., where the output and recommendations of CDSS are solely based on established clinical guidelines. HSA has also provided further examples of nonmedical device CDSS.

Key takeaways

HSA’s continuous updates to its guidelines in relation to SaMDs, especially to bring better alignment with international standards, illustrate that HSA is closely monitoring digital health related developments and will ensure that its guidelines evolve in tandem with advancements in the medical technology space.

* * * * *

LOGO_Wong&Leow_Singapore

© 2025 Baker & McKenzie. Wong & Leow. All rights reserved. Baker & McKenzie. Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a "principal" means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.

Contact Information
Andy Leck
Principal
Singapore
Read my Bio
andy.leck@bakermckenzie.com
Ren Jun Lim
Principal
Singapore
Read my Bio
ren.jun.lim@bakermckenzie.com

Copyright © 2025 Baker & McKenzie. All rights reserved. Ownership: This documentation and content (Content) is a proprietary resource owned exclusively by Baker McKenzie (meaning Baker & McKenzie International and its member firms). The Content is protected under international copyright conventions. Use of this Content does not of itself create a contractual relationship, nor any attorney/client relationship, between Baker McKenzie and any person. Non-reliance and exclusion: All Content is for informational purposes only and may not reflect the most current legal and regulatory developments. All summaries of the laws, regulations and practice are subject to change. The Content is not offered as legal or professional advice for any specific matter. It is not intended to be a substitute for reference to (and compliance with) the detailed provisions of applicable laws, rules, regulations or forms. Legal advice should always be sought before taking any action or refraining from taking any action based on any Content. Baker McKenzie and the editors and the contributing authors do not guarantee the accuracy of the Content and expressly disclaim any and all liability to any person in respect of the consequences of anything done or permitted to be done or omitted to be done wholly or partly in reliance upon the whole or any part of the Content. The Content may contain links to external websites and external websites may link to the Content. Baker McKenzie is not responsible for the content or operation of any such external sites and disclaims all liability, howsoever occurring, in respect of the content or operation of any such external websites. Attorney Advertising: This Content may qualify as “Attorney Advertising” requiring notice in some jurisdictions. To the extent that this Content may qualify as Attorney Advertising, PRIOR RESULTS DO NOT GUARANTEE A SIMILAR OUTCOME. Reproduction: Reproduction of reasonable portions of the Content is permitted provided that (i) such reproductions are made available free of charge and for non-commercial purposes, (ii) such reproductions are properly attributed to Baker McKenzie, (iii) the portion of the Content being reproduced is not altered or made available in a manner that modifies the Content or presents the Content being reproduced in a false light and (iv) notice is made to the disclaimers included on the Content. The permission to re-copy does not allow for incorporation of any substantial portion of the Content in any work or publication, whether in hard copy, electronic or any other form or for commercial purposes.

Delete Comment ?

Are you sure want to delete comment ?

Get link
Embed
Share by email
Get QR Code

Scan this QR Code to share this content

  •  
  •  
  •  
HighQ
Copyright Baker McKenzie 2025 | Disclaimers | Supplemental Privacy Statement