Modernizing Medical Software Regulation in Bangladesh: A Roadmap for Risk-Based SaMD Oversight

Software as a Medical Device (SaMD) has become indispensable in diagnostics, treatment planning, and patient monitoring. While high-income countries have introduced clear regulatory frameworks, Bangladesh and many low- and middle-income countries (LMICs) still lack tailored pathways for medical software approval (IMDRF. Software as a Medical Device (SaMD): Key Definitions (IMDRF/SaMD WG/N10FINAL:(2013)); IMDRF. Software as a Medical Device (SaMD): Clinical Evaluation (IMDRF/SaMD WG/N41FINAL:(2017)); U.S. Food and Drug Administration (FDA). Software as a Medical Device (SAMD): Clinical Evaluation Guidance for Industry and FDA Staff (2017)). The current reliance on manual processes designed for physical devices leads to inefficiencies, inconsistent decisions, and potential risks to patient safety. This Comment proposes a semi-automated, risk-based intake roadmap for Bangladesh's Directorate General of Drug Administration (DGDA). Drawing on IMDRF, EU MDCG, and U.S. FDA frameworks, it presents a tangible workflow showing which submissions can be automatically triaged, which require human review, and where human override is maintained (European Commission (MDCG). Guidance on Qualification and Classification of Software in Regulation (EU) 2017/745 (MDCG 2019-11) and World Health Organization (WHO) Global Model Regulatory Framework for medical devices including IVDs (draft; WHO) (n.d.)). Key intake fields, escalation rules, and measurable performance indicators are defined. Anchored to Bangladesh's current DGDA and national digital health context, the proposal identifies specific legal and infrastructural gaps and outlines steps for phased modernization that may guide other LMICs.