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TGA

Australia · Therapeutic Goods Administration

# Risk-based software rules, with AI evidence rules layered on.

Australia's TGA reformed its software-as-a-medical-device rules in 2021 and has since been bolting AI-specific evidence expectations onto that framework rather than writing a stand-alone AI regulation. The 2024 evidence guidance for AI-enabled software, plus the Feb 2026 refresh of the AI and medical-device software page, are now the operational reference points for any AI SaMD entering the ARTG.

Posture · Developing · AI-specific evidence guidance live since 2024 Last reviewed · May 2026 

Key facts

Reformed software rules in force

Feb 2021

Evidence guidance for AI software

2024 · updated 2026

AI regulation page last updated

Feb 2026

Change posture

Significant change → new inclusion

§01

## How TGA regulates AI-enabled software

AI-enabled software that meets the definition of a medical device is regulated under the Therapeutic Goods (Medical Devices) Regulations 2002, as amended in 2021. Devices are classified using risk-based rules (Class I → Class III / AIMD) with software-specific classification rules (Rules 4.1–4.4 / Schedule 2) introduced in the reform. AI does not change classification logic · it raises the evidence bar, particularly around data, validation, transparency and post-market monitoring.

-   Most diagnostic AI lands Class IIa or IIb under the software classification rules. 
-   Sponsors must hold a conformity assessment (TGA or comparable overseas regulator) before ARTG inclusion. 
-   Evidence package: intended purpose, dataset, validation, human factors, post-market plan. 
-   Australian Unique Device Identifier (AusUDI) work is rolling out and applies to software devices. 

§02

## Evidence requirements for AI software

The TGA evidence guidance for AI software sets out what a sponsor must demonstrate over and above the standard software evidence: clarity of intended purpose, representativeness and quality of training and test data, transparency to users about model behaviour and limitations, and a post-market plan that detects drift and adverse events. It is explicitly aligned with the IMDRF GMLP guiding principles.

-   Document data provenance, inclusion/exclusion criteria, and subgroup performance. 
-   Demonstrate validation on data that is representative of the Australian deployment context. 
-   Provide transparency information · what the model does, what it does not do, its known failure modes. 
-   Operate a post-market monitoring plan with thresholds, escalation, and reporting. 

§03

## Change control: significant change triggers re-inclusion

TGA does not yet have a formal PCCP-equivalent. The default rule is that a significant change to an AI medical device · including retraining that materially alters performance or intended use · requires a new ARTG inclusion or, at minimum, a change notification to TGA. Sponsors are expected to define, in their QMS, what constitutes a significant change for their specific device. AI-specific change-control guidance is on the agency's known workplan.

§04

## Practical posture

Australia is a high-leverage market: the rules are pragmatic, the comparable-overseas-regulator pathway accelerates entry for devices already cleared by FDA / EU / HC, and the evidence expectations are well-telegraphed. The risk is treating it as a copy-paste market. Validation evidence, intended purpose statements, and post-market plans need to be reworked for the Australian context, and change control needs to be planned defensively until formal PCCP guidance lands.

Key takeaways

1.  01 Use the comparable-overseas-regulator pathway where possible, but rework intended purpose and evidence locally. 
2.  02 Align your AI evidence package directly to the 2024/2026 TGA evidence guidance · it is explicit. 
3.  03 Define a 'significant change' policy in your QMS before launch; assume material retraining triggers re-inclusion. 
4.  04 Track TGA workplan updates · formal AI change-control guidance is the next likely deliverable. 

References

-   [TGA · AI and medical device software regulation (Feb 2026) ↗](https://www.tga.gov.au/products/medical-devices/software-and-artificial-intelligence-ai/manufacturing/artificial-intelligence-ai-and-medical-device-software)
-   [TGA · Evidence requirements for software using AI ↗](https://www.tga.gov.au/how-we-regulate/manufacturing/manufacture-medical-device/manufacture-specific-types-medical-devices/evidence-requirements-software-using-ai)
-   [TGA · Understanding how we regulate software-based medical devices (Feb 2026) ↗](https://www.tga.gov.au/resources/guidance/understanding-how-we-regulate-software-based-medical-devices)
-   [TGA · Overview of software and AI lifecycle ↗](https://www.tga.gov.au/resources/guidance/understanding-regulation-software-based-medical-devices)

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