Research of Regulatory Science
LI Yi-ling; ZHAO Qi; WEI Qi-peng; HU Lin-lin*
Objective: This study aims to examine international regulatory experience in artificial-intelligence (AI) medical devices, assess the current status and limitations of China’s regulatory framework, and propose actionable pathways toward a scientific, flexible, and transparent lifecycle regulatory system. Methods: A comparative research approach was adopted, selecting the United States, the European Union, and Japan as representative cases. Their regulatory models were reviewed across four dimensions: approval pathways, prospective algorithm change mechanisms, risk classification, and post-market surveillance, and analyzed in conjunction with China’s recent medical device policies and practices. Results: The United States is characterized by flexible review mechanisms and strong support for innovation; the European Union emphasizes risk prevention and regulatory transparency; and Japan, while maintaining a prudent regulatory foundation, has introduced prospective change management and data-driven post-market monitoring. China has established an initial regulatory framework supported by guidance documents, standards, and technical review requirements, and has made progress in the application of real-world data/evidence (RWD/RWE). Nonetheless, gaps remain in developing prospective regulatory pathways for algorithm updates, refining risk classification and technical specifications, and strengthening interdepartmental coordination. Conclusion: China should draw on international experience to further refine its risk classification system, establish pre-review and dynamic management mechanisms for prospective algorithm changes, promote the systematic use of real-world data, strengthen cross-sector collaboration, and pilot regulatory sandbox initiatives. In particular, it is necessary to build a full lifecycle regulatory framework centered on a closed-loop model of “approval–update–use–monitoring”, thereby improving iterative efficiency while ensuring safety and effectiveness and forming replicable and scalable regulatory practice.