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Checklist Plug-and-play starting point CSV / CSA

Checklist: Part 11 / Annex 11 Minimum Compliant Baseline

A plug-and-play pass/fail checklist against the nine minimum controls a GxP computerized system needs to be defensible under 21 CFR Part 11 and EU Annex 11, for use at go-live gate and periodic review, with a filled specimen.

Document type: Checklist

Read and copy the template below into your own quality system. It is a generic starting point for your own internal use, provided as is, with no warranty; see the Terms and License. Adopting it does not by itself create compliance.

This is a ready-to-use checklist. Replace every <<FILL: ...>> placeholder, mark each item Pass, Fail, or N/A with a reason, and route through your normal QA sign-off. Use it at go-live and again at every periodic review. A filled specimen follows.

Checklist

#ItemPass / Fail / N/AEvidence reference
1A written Part 11 / Annex 11 assessment is on file for this system, mapped to the live version<<FILL>><<FILL>>
2Audit trail is enabled, its coverage is documented, and a defined risk-based review is actually performed and recorded<<FILL>><<FILL>>
3Every user has an individual account; no shared accounts exist; data and administrator roles are segregated<<FILL>><<FILL>>
4An account management procedure covers provisioning, password rules, periodic review, and prompt deprovisioning<<FILL>><<FILL>>
5Electronic signatures display full name, date/time, and meaning; two-component authentication is enforced<<FILL>><<FILL>>
6The one-time §11.100(b) FDA certification letter is on file<<FILL>><<FILL>>
7Backup, restore, retention, and archive retrieval have been tested across the record lifetime, not just at go-live<<FILL>><<FILL>>
8The system clock is controlled and synchronized to a trusted time source<<FILL>><<FILL>>
9A supplier assessment and quality/service agreement exists for any outsourced or hosted component (Annex 11 cl.3)<<FILL>><<FILL>>
10A periodic review procedure reassesses the system, including audit trail review, against changes since the last review<<FILL>><<FILL>>

Disposition

FieldEntry
Number Pass / Fail / N/A<<FILL>>
Any Fail blocks go-live unless formally risk-accepted with an interim control and a closure date<<FILL: list any risk acceptances>>
Reviewer<<FILL: name, date>>
QA approval<<FILL: name, date>>

Filled specimen

System: Manufacturing Execution System recipe module, v6.1. Reviewed at go-live gate, 18 August 2026.

#ItemResultEvidence
1Written assessment on file, mapped to live versionPassAssessment CSV-2026-088, matches v6.1
2Audit trail on, reviewedPassWeekly recipe audit-trail review record, last review 15 Aug
3Individual accounts, segregated rolesFailOne shared “engineering” login used for recipe deployment
4Account management procedurePassIT-SOP-019
5Signatures, two-componentPassTest case TC-77
6FDA certification letterPassOn file with QA, filed 2022
7Backup/restore/retention testedPassRestore test report RT-2026-014
8System clock controlledPassNTP sync configuration verified
9Supplier assessment/agreementPassCurrent agreement, renewed 2026
10Periodic review procedurePassQA-SOP-041, 24-month cycle

Disposition. 9 Pass, 1 Fail, 0 N/A. Item 3 (shared engineering login) is risk-accepted for go-live with an interim control (the shared login is excluded from recipe approval rights, restricted to deployment only, with individual-account remediation due within 60 days). Reviewed by CSV lead, 19 August 2026. Approved by QA, 20 August 2026, with the interim control and closure date documented.

Common inspection findings this checklist prevents

  • A go-live decision made without a documented pass/fail record against the baseline, relying on memory or an informal walkthrough.
  • A Fail item quietly carried forward through periodic review after periodic review with no closure date ever set.
  • Risk acceptance of a Fail item with no interim control specified, just a promise to fix it later.

How to adapt this checklist

  1. Use this exact list at go-live and again at every periodic review so results are comparable over time.
  2. Where an item is genuinely not applicable (for example, no supplier involvement for a fully in-house system), mark N/A with the reason rather than leaving it blank.
  3. Attach this checklist to the validation summary report or periodic review record it supports.
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