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Pharma & MedTech

NIS2 · MDR/IVDR · GxP · ISO 13485

Cybersecurity for Pharma & MedTech

Pharmaceutical manufacturers, medical device manufacturers, and diagnostics companies operate in one of the most heavily regulated environments there is: NIS2, MDR, IVDR, GxP, ISO 13485, FDA 21 CFR Part 11, and EU-GMP Annex 11. At the same time, they are attractive targets for IP theft, production sabotage, and supply chain attacks. We provide awareness training, phishing simulations, vulnerability management, and a managed SOC—tailored to validated systems and audit-ready documentation.

THE REALITY

High IP ratings, long production cycles, extreme downtime costs.

A single day of production downtime in a pharmaceutical facility costs seven-figure sums. A compromised research data set means years of development work and market positions in the hands of competitors. In this industry, cybersecurity is not an IT issue — it is a first-order business risk.

5.10 million dollars

average cost of a data breach in the pharmaceutical sector — the third most expensive sector worldwide after healthcare and finance.

NIS2 + MDR

Parallel obligations under NIS2 for supply security and MDR/IVDR for product safety — with overlapping but not identical documentation requirements.

CSV required

Every system that processes GxP-relevant data is subject to Computer System Validation — every security measure must be documented and validated in an audit-proof manner.

Sources: IBM Cost of a Data Breach Report 2024 · NIS2UmsuCG · MDR (EU) 2017/745 · EU-GMP Annex 11 · FDA 21 CFR Part 11.

THE REALITY

High IP ratings, long production cycles, extreme downtime costs.

A single day of production downtime in a pharmaceutical facility costs seven-figure sums. A compromised research data set means years of development work and market positions in the hands of competitors. In this industry, cybersecurity is not an IT issue — it is a first-order business risk.

5.10 million dollars

average cost of a data breach in the pharmaceutical sector — the third most expensive sector worldwide after healthcare and finance.

NIS2 + MDR

Parallel obligations under NIS2 for supply security and MDR/IVDR for product safety — with overlapping but not identical documentation requirements.

CSV required

Every system that processes GxP-relevant data is subject to Computer System Validation — every security measure must be documented and validated in an audit-proof manner.

Sources: IBM Cost of a Data Breach Report 2024 · NIS2UmsuCG · MDR (EU) 2017/745 · EU-GMP Annex 11 · FDA 21 CFR Part 11.

Regulatory context

Three levels of regulation — supply security, product safety, process integrity.

Pharma and medtech companies operate under several separate regulatory regimes. NIS2 protects the supply of products and services to the public; MDR and IVDR protect patients from unsafe medical devices; GxP and ISO 13485 protect the integrity of the processes in which these products are developed. All three require different — but mutually compatible — forms of evidence.

01 · NIS2

High criticality sector

Manufacturers of medicinal products and medical devices explicitly fall under the health sector pursuant to Annex 1 of the BSIG (high-criticality sector under NIS2 Annex I). From 250 employees or EUR 50 million in annual revenue and EUR 43 million in balance sheet total: particularly important entity. From 50 employees or EUR 10 million in revenue and balance sheet total: important entity. Obligations: risk management pursuant to § 30 BSIG, reporting requirements pursuant to § 32 BSIG, personal liability of management under § 38 BSIG, fines of up to EUR 10 million or 2% of annual revenue (particularly important) or EUR 7 million or 1.4% (important) pursuant to § 65 BSIG.

02 · MDR / IVDR

Product safety for medical devices

MDR (EU) 2017/745 and IVDR (EU) 2017/746 explicitly require IT security for connected medical devices as part of the general safety and performance requirements (Annex I). The MDCG 2019-16 guidance specifies cybersecurity expectations for manufacturers. An incident with a security impact must be reported to BfArM and the notified bodies — within strict deadlines.

03 · GxP / ISO 13485

Validated Systems & QMS

Any system that processes GxP data (production, laboratory, clinical trials) is subject to computer system validation in accordance with EU-GMP Annex 11 and FDA 21 CFR Part 11. Changes must be controlled through change control, and qualifications (IQ/OQ/PQ) must be documented. ISO 13485 requires a quality management system that systematically takes cybersecurity into account as a risk factor.

Legal sources: NIS2UmsuCG · MDR (EU) 2017/745 · IVDR (EU) 2017/746 · MDCG 2019-16 · EU-GMP Annex 11 · FDA 21 CFR Part 11 · ISO 13485 · ISO 14971.

Regulatory context

Three levels of regulation — supply security, product safety, process integrity.

Pharma and medtech companies operate under several separate regulatory regimes. NIS2 protects the supply of products and services to the public; MDR and IVDR protect patients from unsafe medical devices; GxP and ISO 13485 protect the integrity of the processes in which these products are developed. All three require different — but mutually compatible — forms of evidence.

01 · NIS2

High criticality sector

Manufacturers of medicinal products and medical devices explicitly fall under the health sector pursuant to Annex 1 of the BSIG (high-criticality sector under NIS2 Annex I). From 250 employees or EUR 50 million in annual revenue and EUR 43 million in balance sheet total: particularly important entity. From 50 employees or EUR 10 million in revenue and balance sheet total: important entity. Obligations: risk management pursuant to § 30 BSIG, reporting requirements pursuant to § 32 BSIG, personal liability of management under § 38 BSIG, fines of up to EUR 10 million or 2% of annual revenue (particularly important) or EUR 7 million or 1.4% (important) pursuant to § 65 BSIG.

02 · MDR / IVDR

Product safety for medical devices

MDR (EU) 2017/745 and IVDR (EU) 2017/746 explicitly require IT security for connected medical devices as part of the general safety and performance requirements (Annex I). The MDCG 2019-16 guidance specifies cybersecurity expectations for manufacturers. An incident with a security impact must be reported to BfArM and the notified bodies — within strict deadlines.

03 · GxP / ISO 13485

Validated Systems & QMS

Any system that processes GxP data (production, laboratory, clinical trials) is subject to computer system validation in accordance with EU-GMP Annex 11 and FDA 21 CFR Part 11. Changes must be controlled through change control, and qualifications (IQ/OQ/PQ) must be documented. ISO 13485 requires a quality management system that systematically takes cybersecurity into account as a risk factor.

Legal sources: NIS2UmsuCG · MDR (EU) 2017/745 · IVDR (EU) 2017/746 · MDCG 2019-16 · EU-GMP Annex 11 · FDA 21 CFR Part 11 · ISO 13485 · ISO 14971.

TYPICAL ATTACK SCENARIOS

Four attack vectors that specifically target pharma and medtech.

The threat landscape is different from other industries — IP, OT networks, clinical trial data, and deeply integrated supply chains create their own attack patterns that require targeted defense.

OUR SOLUTIONS

Security that respects validated systems.

In GxP-regulated environments, standard security tools fall short of change control and validation requirements. Our program is designed to improve security without compromising the validated status of your systems — with documentation that stands up to audits.

Continuous training

Phishing Simulation as a Service

Industry-specific bait: fake notified body notices, CDMO invoices, regulatory update emails, internal clinical data requests. Measured by department — R&D, QA, Production, Sales. Proof of effectiveness for awareness obligations under NIS2, MDR, and ISO 13485.

Employee Resilience

Security Awareness Training

Role-based training for R&D, production, QA, clinical, regulatory affairs, and sales. Content on IP protection, insider risks, and training on the proper use of USB drives and laboratory equipment. Training records directly usable for ISO 13485, GxP, and NIS2 audits.

Know the attack surface

Vulnerability Management

Asset discovery for OT networks too: SCADA, MES, batch control, LIMS, LabWare. Passive scanning modes for validated systems, active scans only within defined maintenance windows with change-control integration. Remediation tracking that does not compromise qualification status.

24/7 Managed SOC

Incident Detection & Response

Monitoring across IT and OT segments, detection of APT-typical patterns (lateral movement, slow exfiltration, manipulated build pipelines). Prepared reporting documents in accordance with § 32 BSIG for NIS2 and MDR reports to BfArM/notified bodies — within the tight MDR deadlines.

WHY ENTROPY CS

Cybersecurity that understands GxP, validation, and audits.

Generic security service providers run into problems in regulated environments because of validation status. GxP validation specialists, in turn, have no operational security program. We combine both worlds.

Validation-compatible

Our processes are aligned with Change Control, Change Impact Assessment, and qualification requirements. Every security measure is documented in an audit-ready way—no surprises at the next FDA, EMA, or BfArM inspection.

IT and OT perspective

We bring a genuine understanding of the specifics of OT environments — SCADA, MES, lab automation, batch control. No brute-force methods that destroy batches or cost you validation status.

Compliance multi-use

The evidence from our services simultaneously covers NIS2 risk management, MDR cybersecurity documentation, ISO 13485 QMS requirements, and GxP validation evidence. Created once, used multiple times.

Answers specifically for Pharma & MedTech.

Answers specifically for Pharma & MedTech.

The questions we regularly hear from Quality, Compliance, IT leaders and CISOs in pharmaceutical and MedTech companies.

How do you prevent security measures from affecting our validated systems?

How do you prevent security measures from affecting our validated systems?

Which NIS2 category applies to us?

Which NIS2 category applies to us?

How do you handle cybersecurity for our connected medical devices?

How do you handle cybersecurity for our connected medical devices?

We have FDA-relevant systems. Do we need to comply with 21 CFR Part 11 separately?

We have FDA-relevant systems. Do we need to comply with 21 CFR Part 11 separately?

How do you address our supply chain risks?

How do you address our supply chain risks?

How much does that cost for a medium-sized manufacturer?

How much does that cost for a medium-sized manufacturer?

FREE RISK ASSESSMENT

30 minutes. An honest picture of your security posture.

Every conversation begins with a free risk assessment — 30 minutes, no obligation. You will then receive a written report with your cybersecurity maturity level, risk areas, and immediate measures.

FREE RISK ASSESSMENT

30 minutes. An honest picture of your security posture.

Every conversation begins with a free risk assessment — 30 minutes, no obligation. You will then receive a written report with your cybersecurity maturity level, risk areas, and immediate measures.