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White Paper · Data Integrity · AI

Data Integrity
and AI in GxP

What is required, what is proposed, and what still has to be worked out · Version 1.0 · November 2026

How the data integrity rules apply when AI is used in regulated manufacturing and quality systems, across pharma and biotech, medical devices and IVDs, in the EU, UK and US. Our white paper keeps what is in force, what is proposed and what is still open clearly apart.

Summary Slides (PDF)
At a Glance
31 pages
By Niamh St John Lynch, St John Lynch & Co
3 sectors
Pharma and biotech, medical devices and IVDs
EU · UK · US
With notes on PIC/S and MDSAP countries
6 open questions
Where regulators have not yet said how

The Type of Model Is Not the Deciding Factor

Across every sector, regulators are reaching the same position: whether an AI application is acceptable depends on its intended use, the risks it presents and how well those risks are controlled over its lifecycle. For quality teams, that means five things.

1
Data integrity rules already apply to AI
AI-generated records must meet existing predicate rules, with a named person accountable for each. FDA enforced this in a warning letter in April 2026.
2
Document a control strategy for each AI use
Identify the risk scenarios, place a control against each, trace risk to control to evidence, verify that the controls work, and keep monitoring them.
3
Do not plan around the Annex 22 exclusion
The July 2025 draft excluded generative AI and LLMs from critical GMP uses. The EMA's October 2026 workshop report records support for allowing them with a documented, risk-based control strategy.
4
Devices and IVDs already have a requirement
ISO 13485 requires validation of AI tools used in production and the QMS now. A CSA-style record with model-specific content added is a practical way to meet it.
5
Some questions are still open
From keeping test data independent when a model retrains, to what to do when a provider changes the model underneath a qualified process.

No Single Control Catches Every Failure

The EMA's Annex 22 workshop described three layers of control around a model. Each layer addresses particular failure modes, and the regulated record at the end still has a named person accountable for it.

Prevention
before the model runs
  • Context-of-use checks
  • Out-of-distribution checks
  • Rule-based input limits
Detection
during inference
  • Retrieval with source binding
  • Uncertainty measures
  • Consistency across runs
Containment
after the output
  • Confidence gates
  • Human review gate
  • Fallback to a validated state
The regulated record, with a named person accountable for it
Based on Figure 1 of the white paper. Controls designed for known failure modes cannot be assumed to catch unexpected ones.

Clear on What Applies Today

Status Tables

Where Each Instrument Stands

Every relevant instrument for pharma, devices and IVDs across the EU, UK, US and PIC/S, with its date and whether it is in force, a draft or industry guidance.

Control Strategy

From the Workshop to Practice

Layered controls, human oversight versus human-in-the-loop, the AI qualification package, and the supplier and cloud evidence you will need.

Across Sectors

Pharma, Devices and IVDs Compared

Applying CSA to AI, making expert review auditable, the two dimensions of risk, and a side-by-side comparison of how each sector is assessed.

The Summary in Eight Slides

The key points, figure and open questions as a short slide deck. Free to view and easy to share with your team.

Title slide of the Data Integrity and AI in GxP white paper summary deck

Get the Full White Paper

All 31 pages, including the status tables, the cross-sector comparison and 47 references.