Futuristic radiology suite with AI interfaces and FDA badge, representing the intersection of technology and regulation in medical imaging.

AI in Radiology: Navigating the New Regulatory Landscape

"How the FDA's innovative approach to AI regulation is reshaping the future of medical imaging and diagnostics."


Artificial intelligence (AI) is rapidly transforming healthcare, and radiology is at the forefront of this revolution. As AI-powered tools become increasingly prevalent in medical imaging, radiologists are keen on understanding the implications of these advancements. The AI health market is experiencing explosive growth, projected to surge from $600 million in 2014 to $6.6 billion by 2021. This growth underscores the urgent need for clear regulatory guidelines to ensure the safe and effective integration of AI into clinical practice.

Radiologists are particularly invested in AI's development because many significant breakthroughs have occurred in image-based technologies. However, the regulatory landscape is still evolving, and the FDA's approach to overseeing AI development is taking shape. Balancing innovation with patient safety remains a key challenge.

While the FDA has decades of experience regulating drug development, evaluating AI technologies requires a new framework. Recently, the FDA has started focusing on this challenge and is exploring innovative programs to handle AI's unique aspects. This article will delve into the FDA's current strategies for regulating AI in radiology, including the Digital Health Software Precertification Program (Pre-Cert), and discuss the potential impact on radiologists and patient care.

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Radiology’s Share of FDA-Cleared AI

A 2026 roundup reports that the AI medical-imaging market is valued at $3.85 billion and that more than 950 AI devices have FDA clearance, with 76.8% in radiology; it also cites 20% higher cancer detection, 38 minutes saved in stroke triage, and AI adoption at 48% of U.S. hospitals. A separate analysis characterized 1,094 radiology AI devices authorized through December 2025 and found annual authorizations rose 42% over the period studied. Another report gives radiology’s share as 76% of 1,430 FDA-authorized AI/ML devices through December 2025. The reported radiology shares are similar but not identical, and the sources describe different device counts and analyses.

FDA Review and Implementation Challenges

FDA review of radiologic AI includes the agency’s processes for software as a medical device and regulatory designs specific to radiology machine-learning algorithms, with the aim of supporting safety in clinical practice. A 2024 review also discusses challenges that arise when implementing these tools and maximizing their efficacy. In June 2026, the FDA adopted a classification and predicate for radiological machine-learning-based quantitative imaging software with a predetermined change control plan (PCCP); the source describes it as the first device classification incorporating PCCPs into special controls. A 2025 systematic review examines FDA premarket clearances for radiology AI/ML devices, with emphasis on testing.

From Pre-Cert to a Broad Device Cohort

The FDA’s Digital Health Software Precertification Pilot Program explored innovative approaches to regulatory oversight of medical-device software. Later work describes a field with more than one thousand FDA-authorized radiology AI devices and characterizes the devices by function, clinical application, manufacturer segment, and regulatory features. Together, these sources mark a shift from exploring oversight approaches for software to examining the characteristics of a large authorized-device cohort. The supplied material does not provide further details about the pilot’s outcomes or the cohort’s specific findings.

The FDA's Evolving Regulatory Approach

Futuristic radiology suite with AI interfaces and FDA badge, representing the intersection of technology and regulation in medical imaging.

Traditionally, the FDA approves medical devices, including AI-based ones, through pathways like the de novo premarket review. This pathway is designed for new devices that pose low to moderate risk and lack a legally marketed predicate device. Between February and May 2018, the FDA approved three AI-based devices for stroke, diabetic retinopathy, and wrist fracture using this route. This demonstrates the FDA's initial steps in addressing AI in healthcare.

However, recognizing the rapid pace of software development, the FDA introduced new programs to streamline the approval process for software, including AI. One notable initiative is the Digital Health Software Precertification Program (Pre-Cert), announced in April 2018 by then FDA commissioner Dr. Scott Gottlieb. Pre-Cert aims to expedite the regulation of software technology.

  • Faster Approval: Unlike traditional processes that focus on specific products, Pre-Cert provides a pathway for approving entire organizations.
  • Organizational Focus: Once an organization is Pre-Cert approved, it can bring lower-risk products to market without premarket review.
  • Flexibility: The FDA suggests that Pre-Cert may allow firms to make minor device changes without requiring new submissions each time.
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Regulation, Acquisition, and Workflow

A mini-review on AI in anatomic pathology says commercial AI products must obtain marketing approval, such as Conformité Européenne approval or FDA clearance, before they can be legally marketed for clinical use. It identifies successful integration into pathologists’ workflow as the ultimate test for a product. A radiology-focused article notes that addressing regulation, security, and privacy when acquiring AI solutions is complex. These sources highlight that authorization and practical workflow fit are distinct considerations.

Oversight and Liability in AI Workflows

A 2026 article examines how FDA-cleared AI-assisted radiology workflows affect liability, drift monitoring, and radiologist oversight in hospitals. Its supplied summary identifies these as connected issues in the use of cleared tools. The source does not provide comparative findings or specific liability rules, so no conclusions about how liability is allocated can be drawn from the available material.

The Pre-Cert program assesses organizations based on five core principles:

Challenges and the Path Forward

While the Pre-Cert program offers a promising approach, it also raises important questions. Vetting organizations instead of individual products is unprecedented, creating concerns about monitoring safety and efficacy. The FDA is actively working on defining different levels of certification and ensuring that organizations maintain their Pre-Cert status over time.

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Pre-Cert and Software Market Entry

In April 2018, FDA commissioner Dr. Scott Gottlieb announced development of the Digital Health Software Precertification Program, also known as Pre-Cert. The program sought to streamline regulation of software technology, including AI products. The source presents Pre-Cert as a new program intended to change how software products come to market.

Uneven Adoption and Expanding Technologies

A 2025 overview reports that hundreds of AI-enabled tools had received regulatory clearance for medical-imaging tasks by late 2025. It describes clinician adoption as growing but uneven around the world. A second 2025 overview covers FDA authorizations, clinical adoption rates, and technologies ranging from convolutional neural networks to foundation models for medical imaging. The supplied summaries do not give specific adoption rates or forecasts.

Planned Changes Through PCCPs

A predetermined change control plan (PCCP) describes anticipated device modifications, the methodology for developing, validating, and implementing them, and an assessment of their impact. PCCPs can apply to radiology-specific devices. The source says they are frequently used to retrain or optimize AI algorithms with additional datasets. This offers a defined way to describe planned changes to an AI device.

Radiologists’ Knowledge and Attitudes

A cross-sectional study examines Norwegian radiologists’ knowledge and attitudes toward artificial intelligence. Its supplied summary states that AI solutions have been approved and adopted in radiology. The summary provides no results about the radiologists’ specific knowledge, attitudes, or experiences, so those findings cannot be characterized from the available material.

Establishing a robust framework for risk stratification is critical. The FDA plans to use the International Medical Device Regulators Forum framework, which categorizes risk based on the patient's situation (critical, serious, or nonserious) and how the device's information will be used (inform clinical management, drive clinical management, or treat and diagnose). However, real-world implementation may prove challenging due to the lack of established precedents.

Some healthcare experts worry that the Pre-Cert approach could give software an implicit stamp of approval without sufficient clinical validation. As the FDA continues to refine its regulatory strategies, radiologists must stay informed and actively participate in shaping these changes. The first official version of the Pre-Cert program (Pre-Cert 1.0) is expected in December 2018, necessitating ongoing collaboration with the FDA to ensure a safe, effective, and patient-centered approach to AI in radiology.

Clinical testing alongside radiology AI authorizations

  • 5% and 29%Among radiology devices with submission documentation, 33 of 717 (5%) had prospective testing, while 208 of 717 (29%) incorporated clinical testing.[1]

What the testing figures say about the evidence base

Clinical testing appeared in a minority of the documented submissions, and prospective testing was less common still. These counts describe testing recorded in submission documents, not whether a tool performs well in every clinical setting.[1]

How testing and market entry compare across the evidence

The same analysis reports that the 510(k) pathway accounted for most authorizations, while noting that this route does not require independent clinical data demonstrating performance or safety. The pathway’s efficiency therefore should not be read as proof that each device has independent clinical evidence.[1]

The analysis was limited by variation in FDA summary-document completeness, possible underreporting of testing, and exclusion of tools outside FDA clearance. Those constraints mean its testing figures characterize available documentation rather than every AI tool in use.[1]

About this Article -

Written with AI assistance from published research, and reviewed by the Mystum team. See our About page for more information.

This article is based on research published under:

DOI-LINK: 10.1016/j.jacr.2018.09.057, Alternate LINK

Title: The Fda And Artificial Intelligence In Radiology: Defining New Boundaries

Subject: Radiology, Nuclear Medicine and imaging

Journal: Journal of the American College of Radiology

Publisher: Elsevier BV

Authors: Samantha G. Harrington, Monica K. Johnson

Published: 2019-05-01

Everything You Need To Know

1

What is the Digital Health Software Precertification Program (Pre-Cert)?

The Digital Health Software Precertification Program (Pre-Cert) is a program introduced by the FDA to streamline the approval process for software, including AI, in healthcare. It shifts the focus from individual product approvals to evaluating the organization developing the software. If an organization is Pre-Cert approved, it can bring lower-risk products to market without premarket review, offering a faster route to market compared to traditional processes.

2

Why is the FDA changing its regulatory approach to AI in radiology?

The FDA is adapting to the rapid development of AI technologies in radiology, and the Pre-Cert program is a key part of this adaptation. The FDA's traditional pathways, like the de novo premarket review, are being supplemented by programs like Pre-Cert to keep pace with innovation. The Pre-Cert program's organizational focus allows for more agile regulation, which is critical for the fast-paced development cycles of AI software. It allows for faster approval and flexibility in making minor changes to the devices without requiring new submissions.

3

How does the Pre-Cert program work to regulate AI?

The Pre-Cert program is designed to address the challenges of regulating rapidly evolving software technology. Unlike the traditional approach of evaluating individual products, Pre-Cert assesses the organization itself. This approach aims to expedite the approval process, allowing organizations to bring lower-risk products to market more quickly. It emphasizes organizational culture and quality systems, and monitoring, and aims to allow organizations to adapt and make minor changes to software more easily, which is vital for the iterative nature of AI development.

4

What are the implications of the Pre-Cert program for radiologists and patient care?

The implications of the Pre-Cert program are significant for radiologists and patient care. By speeding up the approval process, the program enables faster access to potentially beneficial AI tools for diagnostics and image analysis. This could improve efficiency and accuracy in radiology, ultimately leading to better patient outcomes. The Pre-Cert program also introduces new considerations for radiologists, such as the importance of understanding the organizational quality and processes behind the AI tools they use. It is still evolving, and the FDA is working on defining different levels of certification to ensure that organizations maintain their Pre-Cert status over time.

5

How does the de novo premarket review pathway compare to the Pre-Cert program?

The FDA approved three AI-based devices for stroke, diabetic retinopathy, and wrist fracture using the de novo premarket review pathway between February and May 2018. The Pre-Cert program is a more recent development. Both strategies demonstrate the FDA's effort to address AI in healthcare. While the de novo pathway focuses on individual devices, the Pre-Cert program aims to streamline the process for software by focusing on the organization's overall quality and processes.

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