PV Bulletin

eMDR System Enhancements - Production Deployment

The FDA is implementing enhancements to the eMDR system, introducing stricter validation rules and transitioning to GENC codes.

Primary source: Food and Drug Administration (FDA)

PV Impact Brief

Urgency: HighConfidence: high

What changed

Introduction of stricter technical validation rules for electronic submissions; reports lacking fields B5 (event description) and H1 (reportable event type) in Form 3500A will be rejected starting July 20, 2026. ISO 3166-1 alpha-2 country codes will no longer be accepted.

Why it matters

This change ensures accurate and compliant reporting in line with international standards, impacting all users of the eMDR system and potentially affecting the usability of electronic safety reporting systems.

Action needed

Update electronic safety reporting systems and pharmacovigilance databases to implement new rules to ensure all submissions use GENC 3-letter country codes and include the required fields as of July 20, 2026.

Relevant for
Regulatory Intelligence LeadQPPV
Processes impacted
ICSRCountry Compliance
Owner

Regulatory Intelligence Lead

Review cadence

Review before 2026-06-29.

Policy change details

Document type
Notice
Policy status
final
Publication date
2026-07-20
Coming into force
2026-07-27
Effective date
2026-07-20
Policy change
The FDA announced the production deployment of eMDR system enhancements, scheduled for July 27, 2026, which includes consolidation with the Adverse Event Monitoring System (AEMS) and adoption of IMDRF 2025 maintenance updates. This update requires AS2/API submitters to transition from ISO 3166-1 alpha-2 country codes to GENC 3-letter codes to align with the XML specification. A scheduled maintenance outage is planned for July 22-27, 2026, during which Ack3 and Ack4 messages will be delayed.

Key changes

Scheduled maintenance outage from July 22 to July 27, 2026; mandatory transition to GENC 3-letter country codes for electronic submissions; implementation of IMDRF 2025 maintenance updates for Adverse Event problem codes in sections F10 and H6 of Form 3500A; minor changes to Ack3 error messages due to AEMS consolidation.

Affected workflows

ICSRCountry Compliance

Responsible groups

PV OperationsIT/Safety SystemsRegulatory Affairs

PV impact

Manufacturers and importers of medical devices must update their electronic reporting systems and internal coding libraries to support GENC 3-letter country codes and updated IMDRF AE codes. PV operations should account for the July 22-27 outage window by including a specific statement in Block H11 for impacted reports and preparing for delays in receiving electronic submission acknowledgments. System updates for AS2/API users must be completed by March 31, 2027.

View regulator source

Source document details

Exact policy details

Scheduled Outage
July 22, 2026, 7:00 PM EST to July 27, 2026, 9:00 AM EST
Applies to: All users submitting to eMDR
There will be a scheduled outage from July 22, 2026, 7:00 PM EST to July 27, 2026, 9:00 AM EST for this deployment. · p. 1 · High · Source
ISO Code Acceptance Change
No longer accepting ISO 3166-1 alpha-2 country codes
Applies to: AS2/API submitters
With the AEMS consolidation, eMDR will begin rejecting ISO 3166-1 alpha-2 country codes. · p. 1 · High · Source
XML Specification Compliance Deadline
August 2024
Applies to: All users of eMDR
Please review the eMDR Implementation Package and verify that all systems comply with the August 2024 XML specification. · p. 1 · High · Source
Impact Statement Requirement
Include statement in Block H11 of FDA 3500A form or equivalent
Applies to: Submitters whose reports are impacted by scheduled maintenance
Submitters with reports impacted by this scheduled downtime should include the following statement in Block H11 of the FDA 3500A form or equivalent: “This report was impacted by eMDR scheduled maintenance occurring July 22-27, 2026.” · p. 1 · High · Source

Workflow rule impacts

ICSRSubmitters

Delay in acknowledgment messages Ack3 and Ack4 during outage; submitters should avoid submissions.

Outage period for electronic submissions

Any submissions sent during this time will receive Ack1 and Ack2 as usual, but Ack3 and Ack4 will be delayed. · p. 1 · High · Source
LabelingSubmitters

Submitters must transition to GENC 3-letter country codes for accurate submissions.

No longer accepting specific country codes

eMDR will begin rejecting ISO 3166-1 alpha-2 country codes, which are not compliant with the XML specification. · p. 1 · High · Source

Extracted documents

Unable to extract linked source document: https://www.googletagmanager.com/ns.html Unable to extract linked source document: https://www.hhs.gov/vulnerability-disclosure-policy/index.html

Evidence and confidence

Confidence: highSource updated: Jun 29, 2026

Full briefing

Practical implication

Update electronic safety reporting systems and pharmacovigilance databases to implement new rules to ensure all submissions use GENC 3-letter country codes and include the required fields as of July 20, 2026.

The FDA’s eMDR system will undergo significant enhancements including the rejection of reports missing critical fields and the transition from ISO 3166-1 alpha-2 country codes to GENC alpha-3 codes. Compliance updates are required by July 20, 2026, to avoid report rejections.

What changed: Introduction of stricter technical validation rules for electronic submissions; reports lacking fields B5 (event description) and H1 (reportable event type) in Form 3500A will be rejected starting July 20, 2026. ISO 3166-1 alpha-2 country codes will no longer be accepted.

Why it matters: This change ensures accurate and compliant reporting in line with international standards, impacting all users of the eMDR system and potentially affecting the usability of electronic safety reporting systems.

Practical implication: Update electronic safety reporting systems and pharmacovigilance databases to implement new rules to ensure all submissions use GENC 3-letter country codes and include the required fields as of July 20, 2026.

View original source

Published from the Firecrawl policy change extraction pipeline.

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