Under EU MDR Article 61 and Annex XIV, every medical device — every risk class, no exceptions — must have a Clinical Evaluation Report (CER) as part of its technical documentation. The CER is not a literature review, not a summary, and not a formality. It is a systematically structured document that evaluates all available clinical evidence to demonstrate that the device achieves its intended clinical benefit, that risks are acceptable relative to benefits, and that the evidence is sufficient for CE marking.
Notified Bodies consistently identify CER deficiencies as one of the top causes of nonconformities. The 2024 MedTech Europe MDR/IVDR Survey reported that clinical documentation and technical documentation assessment remain the most frequent sources of review findings, and multiple Notified Bodies cite incomplete clinical evidence and weak CER structure as recurring issues. The gap between a CER that passes review and one that triggers a multi-page deficiency letter is often a matter of structure and traceability — not necessarily the underlying data.
This article provides a complete CER template with section-by-section guidance, example tables, and an evidence traceability matrix. It is a companion to our Clinical Evaluation Report Complete Guide — use that article for methodology and process guidance, and this template to build your actual document.
Regulatory Basis and Key References
Before using this template, understand the governing framework:
Reference
Content
Role
EU MDR Article 61
Legal requirement for clinical evaluation
Primary legal basis
EU MDR Annex XIV, Part A
Clinical evaluation process and minimum requirements
Process requirements
EU MDR Annex XIV, Part B
Clinical investigation requirements
When clinical investigation is needed
MEDDEV 2.7/1 Rev. 4
Clinical evaluation methodology guidance (still referenced by NBs)
Methodology
MDCG 2020-13
Clinical evaluation assessment report template for NBs
[Search protocol ID], databases searched, date range
Directly applicable
Literature — equivalent device
Systematic literature review
[Search protocol ID], equivalence justified per Section 4
Applicable if equivalence demonstrated
Other clinical experience
Registries, published case series
[Registry name], n=[X]
Supportive
Published safety data
Vigilance databases, MAUDE, BfArM
[Query results ID]
Safety signals
3.2 Literature Search Protocol Summary
Parameter
Detail
Databases searched
PubMed/MEDLINE, Cochrane, Embase, [others]
Search date range
[Start date] to [End date]
Search terms
[List key terms and Boolean logic]
Inclusion criteria
[Population, intervention, comparator, outcomes, study design]
Exclusion criteria
[Specific exclusion criteria]
Number of hits (initial)
[X]
Number after title/abstract screening
[X]
Number after full-text review
[X]
Number included in analysis
[X]
3.3 PRISMA Flow Diagram Reference
Include a PRISMA (Preferred Reporting Items for Systematic Reviews and Meta-Analyses) flow diagram showing the literature search screening process. This is increasingly expected by Notified Bodies per 2026 guidance.
If clinical data from an equivalent device is used, the manufacturer must demonstrate equivalence per MDCG 2020-5 and Annex XIV Section 3. Three dimensions must be assessed:
Equivalence Assessment Table
Aspect
Characteristic
Proposed Equivalent Device
Your Device
Equivalent?
Justification
Technical
Intended purpose
[Description]
[Description]
Yes/No
[Explanation]
Technical
Principle of operation
[Description]
[Description]
Yes/No
[Explanation]
Technical
Design
[Description]
[Description]
Yes/No
[Explanation]
Technical
Materials (contact)
[Description]
[Description]
Yes/No
[Explanation]
Technical
Manufacturing processes
[Description]
[Description]
Yes/No
[Explanation]
Technical
Surface treatment/coating
[Description]
[Description]
Yes/No
[Explanation]
Technical
Software algorithm
[Description]
[Description]
Yes/No
[Explanation]
Biological
Tissue contact type
[Description]
[Description]
Yes/No
[Explanation]
Biological
Duration of contact
[Description]
[Description]
Yes/No
[Explanation]
Biological
Biocompatibility profile
[Description]
[Description]
Yes/No
[Explanation]
Biological
Substance release
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Clinical condition
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Severity and stage of disease
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Site of application
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Target population
[Description]
[Description]
Yes/No
[Explanation]
Clinical
User profile
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Clinical performance outcomes
[Description]
[Description]
Yes/No
[Explanation]
Clinical
Critical performance assessment
[Description]
[Description]
Yes/No
[Explanation]
Critical requirement: The manufacturer must have sufficient access to the technical documentation of the equivalent device to justify the technical and biological characteristics. If access is limited, equivalence cannot be claimed — a clinical investigation may be required instead.
Section 5: Clinical Data Appraisal
5.1 Data Appraisal Table
For each included clinical data source, assess its quality and relevance:
Study/Data Source
Study Design
Sample Size
Follow-up
Population Relevance
Methodological Quality
Data Weighting
[Study 1: Author, Year]
RCT / prospective / retrospective
n=
[Duration]
High/Medium/Low
High/Medium/Low
High/Medium/Low
[Study 2]
...
...
...
...
...
...
[PMCF Registry]
Registry
n=
[Duration]
High
Medium
Medium
[Literature — equivalent]
Systematic review
n=
[Duration]
Medium
High
Medium
5.2 Quality Assessment Criteria
Quality Level
Criteria
High
Well-designed RCT or large prospective study; adequate sample size; appropriate controls; long-term follow-up; relevant endpoints
Medium
Well-designed non-randomized study; prospective cohort; registry with good data quality; adequate follow-up
Low
Retrospective study; case series; small sample size; short follow-up; potential confounding
Section 6: Clinical Data Analysis
6.1 Performance Outcomes Table
Clinical Endpoint
Target (from IFU claims)
Observed Result
Confidence Interval
Source(s)
Meets Claim?
[Primary endpoint 1]
e.g., ≥90% fusion rate
[X]%
[CI]
[Study refs]
Yes/No
[Primary endpoint 2]
e.g., ≤5% complication rate
[X]%
[CI]
[Study refs]
Yes/No
[Secondary endpoint 1]
e.g., VAS pain reduction ≥50%
[X] points
[CI]
[Study refs]
Yes/No
[Safety endpoint 1]
e.g., ≤2% serious adverse events
[X]%
[CI]
[Study refs]
Yes/No
6.2 Safety Data Summary Table
Adverse Event Category
Frequency (Own Data)
Frequency (Literature)
Severity
Related to Device?
Adequately Controlled?
[AE Category 1]
[X]% (n/N)
[X]% (range)
[Mild/Moderate/Severe]
Yes/No/Unlikely
Yes/No
[AE Category 2]
[X]% (n/N)
[X]% (range)
[Mild/Moderate/Severe]
Yes/No/Unlikely
Yes/No
Section 7: Benefit-Risk Analysis
7.1 Benefit-Risk Summary Table
Aspect
Assessment
Identified benefits
[List all clinical benefits with magnitude]
Identified risks
[List all risks with frequency and severity]
Risk mitigation measures
[Design features, IFU warnings, training requirements]
Residual risks
[Risks remaining after mitigation]
Benefit-risk conclusion
[Statement: benefits outweigh risks under conditions of use]
7.2 Benefit-Risk Assessment per ISO 14971 Alignment
Link the clinical benefit-risk assessment to the risk management file:
Risk (from RM File)
Clinical Evidence Addressing This Risk
Risk Level After Clinical Evidence
Acceptable?
[Risk 1 from RM file]
[CER Section reference + evidence]
[Low/Medium/High]
Yes/No
[Risk 2 from RM file]
[CER Section reference + evidence]
[Low/Medium/High]
Yes/No
Section 8: GSPR Compliance Through Clinical Evidence
Map clinical evidence to the specific GSPR that it supports:
GSPR No.
GSPR Requirement
Clinical Evidence Provided
CER Section Reference
GSPR Compliant?
GSPR 1.1
Achieves intended performance
[Evidence summary]
Section 6.1
Yes
GSPR 1.8
Benefits outweigh side effects
[Benefit-risk analysis]
Section 7
Yes
GSPR 1.9
State of the art considered
[SOTA comparison]
Section 2.5
Yes
[Additional GSPR]
[Requirement]
[Evidence]
[Section]
[Status]
Section 9: Data Gaps and PMCF Linkage
This section is critical. Every identified gap in the clinical evidence must be linked to a specific PMCF activity.
9.1 Clinical Data Gap Table
Gap ID
Data Gap Description
Affected GSPR/Claim
PMCF Activity to Address Gap
PMCF Plan Reference
Expected Timeline
GAP-001
[e.g., Limited long-term data (>5 years) for new coating]
GSPR 1.6
PMCF registry study, 10-year follow-up
PMCF Plan Section 4.2
2026–2031
GAP-002
[e.g., No clinical data in pediatric subpopulation]
GSPR 1.9
PMCF survey of off-label pediatric use
PMCF Plan Section 4.3
2026 Q3
GAP-003
[e.g., Equivalence not fully established for software algorithm]
GSPR 14.7
PMCF clinical performance study
PMCF Plan Section 4.4
2026–2027
9.2 PMCF-CER Cross-Reference
PMCF Activity
CER Gap Addressed
Current PMCF Status
Next PMCF Data Expected
CER Update Triggered?
[Activity 1]
GAP-001
[Ongoing/Planned/Complete]
[Date]
Yes/No
[Activity 2]
GAP-002
[Ongoing/Planned/Complete]
[Date]
Yes/No
Section 10: Conclusions
10.1 Conclusion Statements
Statement
CER Section Reference
The clinical evidence is sufficient to demonstrate conformity with relevant GSPR
Section 8
The device achieves its intended clinical benefits as claimed
Section 6.1
The identified risks are acceptable in relation to the benefits
Section 7
The state of the art has been appropriately considered
Section 2.5
Data gaps are identified and addressed by PMCF activities
Section 9
The clinical evaluation will be updated per the defined schedule
Section 1.7
10.2 Conditions for Conformity
List any conditions under which the conclusions hold (e.g., specific patient populations, use environments, training requirements, or follow-up schedules).
Section 11: Dates, Signatures, and Revision History
Revision History Table
Version
Date
Author
Description of Change
1.0
[Date]
[Author]
Initial CER
1.1
[Date]
[Author]
Updated literature search; added PMCF data from [study]
1.2
[Date]
[Author]
Addressed NB deficiency [ref]; updated equivalence assessment
Based on Notified Body feedback patterns and industry experience:
Write in the third person — the CER is an objective evaluation, not an advocacy document
Define all terms — avoid unexplained jargon; if you use "equivalent device," define which device and justify equivalence in Section 4
Support every statement with a source — trace every claim to a specific data source, test report, or published reference
Use tables over prose — Notified Body reviewers scan tables faster than paragraphs; convert narrative descriptions to structured tables wherever possible
Tell a coherent clinical story — the CER should read as a logical progression from device description through evidence to conclusions, not a collection of disconnected sections
Address unfavorable data — omitting contradictory evidence destroys credibility; acknowledge it and explain why it does not undermine the overall conclusion
Draft CER and PMCF Plan in parallel — the two documents must cross-reference each other explicitly; create a formal data gap table in the CER, then map each gap to a specific PMCF activity
Common CER Nonconformities and How This Template Prevents Them
NB Nonconformity
Root Cause
How This Template Addresses It
"Insufficient clinical evidence to support performance claims"
Claims not mapped to data
Evidence Traceability Matrix (Claim ID → Data Source)
"Equivalence not adequately justified"
Only clinical comparability assessed, not technical/biological
Three-dimension Equivalence Table (Section 4)
"Literature search methodology not documented"
No search protocol included
Literature Search Protocol Summary (Section 3.2) + PRISMA diagram