Compliance (CSV)

A binder full of test protocols
is not yet a validated state.

Method domain — bringing systems into the validated state. Without CSV there is no validated system state: Annex 11 requires it, and GAMP 5 is the established framework in which it is produced. Enterprise Service Management cannot take the work over: it maintains the state, it does not establish it.

Regulatory anchor

Annex 11 requires the validated system state and draws a distinction: the application is validated, the IT infrastructure is qualified. The extent is decided by a justified and documented risk assessment. GAMP 5 is the established framework in which that state is produced; for determining validation depth on a risk basis, ICH Q9 (Quality Risk Management) applies — incorporated in the EU through Part III of the GMP guide and, since July 2023, in its Q9(R1) revision.

GAMP 5

ISPE guide, 2nd edition 2022 — risk-based framework

Annex 11

EU GMP guideline for computerized systems, in force since 2011

21 CFR Part 11

FDA rule on electronic records and signatures, in force since 1997

IQ · OQ · PQ

Qualification phases within the project

Regulatory trigger

The drafts revising Annex 11, the new Annex 22 and the revision of GMP Chapter 4 were published on 7 July 2025; the consultation closed on 7 October 2025 and no final versions exist. The need for advice arises with the finalization and transition period of the whole package, not with Annex 22 alone — and largely independently of whether a company uses AI at all.

What we design here

The validated state, established in the single project.

Application

validated

IT infrastructure

qualified

The extent is decided by a justified and documented risk assessment — the unit: the single validation project.

The validation project from requirement through specification to documented acceptance

The project is complete when acceptance is documented and the system is released for productive operation. That release is the handover point.

Validation planning

The validation master plan is the foundation of every CSV activity. We develop it together with your QA and IT teams.

URS, FS and DS as a specification chain

URS, FS and DS build on one another; the testing scope derives from them. No test without a requirement.

Test documentation within the project — IQ/OQ/PQ and traceability matrix

IQ, OQ, PQ — structured and traceable. We create test plans, support execution and document deviations and their resolution. The traceability matrix ties every requirement to its evidence.

Risk management: structured risk analyses under ICH Q9 as the basis for validation depth — with proportionate controls

Building blocks in the field

Migration verification

System types that get validated

ERP (SAP, MS Dynamics) LIMS DMS / document systems MES QMS software Laboratory software SCADA / PLC Label management systems (LMS) AI applications SaaS solutions

Label management systems fall under GAMP 5 category 4 or 5 — subject to validation, including the print process, approval workflow and audit trail.

Label management in GxP environments →

Boundary

Where Compliance (CSV) ends.

CSV establishes the validated state. Evidence across system boundaries sits with Test Management; the dividing line is scope — a single project versus the lifecycle and the system landscape. Operation sits with Enterprise Service Management, the handover point being release to productive operation.

We deliver: validation planning, specification chain, qualification, test documentation

QA delivers: the rules for implementation and lifecycle

Discuss your validation project?

Together, we accomplish what doesn't get finished alone.

Contact us