The EU AI Act: What It Means for Pharma, MedTech, and the Future of Healthcare

The EU Artificial Intelligence Act (EU AI Act) has fundamentally transformed the regulatory environment for artificial intelligence (AI) throughout Europe, with healthcare experiencing the most notable impact.

The EU AI Act: What It Means for Pharma, MedTech, and the Future of Healthcare

The EU AI Act came into effect in 2024 and is the first comprehensive legal framework worldwide for AI.1 Aimed at making AI safe, transparent, and trustworthy, it establishes a risk-based regulatory approach that influences how AI is developed and used within the healthcare sector.2,3   For pharmaceutical companies and medical device manufacturers, the Act functions not only as a compliance obligation but also as a catalyst for redefining digital innovation. Since its launch, the healthcare industry has been progressively implementing it, with high-risk AI requirements expected to come into effect from 2027. 

Understanding the EU AI Act

At its core, the Act classifies AI systems into four categories:

  • Minimal risk - largely unregulated
  • Limited risk - transparency obligations
  • High risk - tightly regulated systems affecting health, safety, or fundamental rights
  • Unacceptable risk - prohibited uses such as manipulative or exploitative AI

Healthcare technologies are predominantly classified as high risk due to their significant potential impact on patient outcomes. The Act complements existing EU health legislation rather than replacing it.

Why Healthcare Is Uniquely Impacted

Medical Devices and SaMD Are Automatically High Risk

Any AI system integrated into a medical device or an in vitro diagnostic device is considered high-risk. This includes: diagnostic imaging AI, clinical decision support tools, remote monitoring algorithms and software as a Medical Device (SaMD). Manufacturers are now required to comply with both the MDR/IVDR and the AI Act, creating a dual regulatory pathway that demands more rigorous documentation, testing, and oversight.

Pharma Is Affected in Targeted Ways

Pharmaceutical companies have fewer direct obligations; however, several areas are still covered by the Act. These include AI used in clinical trials, AI supporting benefit–risk assessments, Patient facing digital therapeutics and AI used in pharmacovigilance or safety monitoring. Research-only AI is largely exempt; however, once an AI system affects patient care or regulatory filings, the Act applies.

Key Requirements for High Risk Healthcare AI

High-risk systems are required to comply with strict obligations, such as:

  • Accuracy, Robustness, and Cybersecurity
  • Data Governance and Training Data Controls
  • Documentation and CE Marking Integration
  • Human Oversight
  • Risk Management and Quality Systems
  • Transparency and Explainability

For MedTech companies, this involves integrating AI-specific controls into their current quality management systems.

Implications for the Healthcare Sector

The healthcare sector needs to consider several factors that could impact product development.

Stronger Data Governance: Healthcare AI must demonstrate data accuracy, bias mitigation, traceability and security and privacy protections. This elevates the standards for datasets employed in model training and validation.

Longer Development Timelines: More comprehensive testing and documentation could lengthen development timelines, particularly for AI enabled medical devices. Organisations will have to allocate resources to data governance teams, algorithmic auditing and model explainability tools.

Regulatory expertise: Non-EU companies deploying AI systems in the EU market must comply with the regulations, thereby turning the Act into a de facto global standard.

How Healthcare Organisations Can Prepare

To maintain a competitive edge, companies need to:

  • Map all AI systems and classify them by risk
  • Integrate AI Act requirements into MDR/IVDR processes
  • Strengthen data governance and documentation
  • Establish human oversight frameworks
  • Begin preparing for 2026–2027 compliance deadlines

Although it introduces additional regulatory requirements, it provides several benefits, including harmonisation of EU-wide standards, increased investor and patient trust, clear market access rules, and global regulatory influence. Ultimately, the framework should help to accelerate the adoption of trustworthy medical AI across Europe.

Join our new training course, The 2024 EU (European Union) AI Act Training Course and learn how healthcare organisations are proactively planning to maintain competitiveness and maximise opportunities.

References

  1. European Parliament and Council of the European Union. Regulation (EU) 2024/1689 of the European Parliament and of the Council of 12 July 2024 Laying Down Harmonised Rules on Artificial Intelligence (Artificial Intelligence Act) and Amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828. Official Journal of the European Union. 13 June 2024. https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng
  2. European Medicines Agency (EMA). Reflection Paper on the Use of Artificial Intelligence in the Medicinal Product Lifecycle. Amsterdam: EMA; 9 September 2024. https://www.ema.europa.eu/system/files/documents/scientific-guideline/reflection-paper-use-artificial-intelligence-ai-medicinal-product-lifecycle-en.pdf
  3. European Commission Medical Device Coordination Group (MDCG). MDCG  2019-11 Rev.1 
    Guidance on Qualification and Classification of Software in Regulation (EU) 2017/745 – MDR and Regulation (EU) 2017/746 – IVDR. October 2019  June 2025 rev.1. https://health.ec.europa.eu/document/download/b45335c5-1679-4c71-a91c-fc7a4d37f12b_en

Published on May 18, 2026 by

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