AR Obligations
Overview
The full obligations of an Authorized Representative are set out in MDS-REQ 9. The AR is not simply a postal address — they carry significant regulatory responsibility throughout the device lifecycle.
Registration and application obligations
- Submit MDMA applications via GHAD on behalf of the manufacturer
- Ensure all documentation meets SFDA requirements before submission
- Pay application and registration fees on behalf of the manufacturer (reimbursed by arrangement)
- Respond to SFDA queries and deficiency letters during review
- Receive and hold the MDMA certificate
Post-market obligations
- Adverse event reporting — report serious incidents and near-incidents to the NCMDR within required timeframes
- FSCA coordination — manage Field Safety Corrective Actions in Saudi Arabia; issue Arabic and English Field Safety Notices
- Distribution tracking — maintain records of device distribution in KSA
- PSUR/PMS — ensure PMS and PSUR data are collected and documented per class requirements
- MDMA renewal — submit renewal applications before certificate expiry
Change notification
- Notify the SFDA of any significant changes to the device (design, intended use, manufacturing site, labelling)
- Assess whether a change triggers re-submission vs. simple notification
QMS
The AR must implement and maintain a QMS certified to ISO 13485 (SFDA.MD/GSO ISO 13485). This applies to the AR's own regulatory management activities, not to the device's manufacturing QMS.
Labelling compliance
- Ensure the AR's current name and address appear on all device labels, packaging, and IFU
- Ensure home-use device labels carry Arabic content
- Obtain SFDA pre-approval for advertising materials (MDS-REQ 8)
Further reading
- MDS-REQ 9 — Full AR obligations
- AR Overview
- Changing Your AR