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Validation Requirements and Responsibilities

Clarify validation responsibilities for SaaS and cloud systems, leverage vendor evidence, apply CSA principles, and close GxP validation gaps with risk-based controls.

Validation Requirements and Responsibilities
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Clarify validation responsibilities for SaaS and cloud systems, leverage vendor evidence, apply CSA principles, and close GxP validation gaps with risk-based controls.

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Validation does not have to mean recreating every vendor test, rewriting every artifact, or burying teams under documentation nobody wants to read twice. The better path is knowing what the vendor can provide, what the regulated company still owns, and where risk-based evidence must close the gap.

This white paper helps life sciences teams clarify validation requirements and responsibilities for SaaS and cloud systems, including how to leverage vendor SDLC, testing, release management, documentation, and support while maintaining GxP accountability.

Use it to make validation more efficient, more defensible, and slightly less soul-taxing. We take our wins where we can.

What you will learn

  • Clarify responsibility boundaries: understand what vendors typically provide and what the regulated company must still own.
  • Leverage vendor evidence: use SDLC documentation, OQ testing, traceability, release notes, and support artifacts without duplicating low-value work.
  • Apply CSA principles: focus validation effort on intended use, risk, critical thinking, automated testing, and patient/product-quality impact.
  • Close validation gaps: identify where customer-specific configuration, PQ, data integrity, change control, and ongoing maintenance require additional evidence.

Why validation responsibility matters

As life sciences organizations rely more heavily on SaaS and cloud technology vendors, validation becomes a shared-evidence model. Vendors may provide development controls, testing, documentation, release management, and support. The regulated company remains accountable for intended use, configuration, risk assessment, data integrity, and operational control.

FDA’s Computer Software Assurance guidance supports leveraging vendor testing and release management where appropriate. The opportunity is to reduce redundant work while keeping the validation package clear enough to defend during audits and inspections.

USDM point of view Validation efficiency comes from smart evidence leverage, not blind vendor trust. Know what you can rely on, what you must verify, and what you still need to control.

KPIs to measure validation efficiency and control

Track metrics that show whether validation work is risk-based, traceable, and sustainable across releases.

Program metrics to track
LeverageVendor evidence acceptedApproved vendor SDLC, OQ, traceability, and release artifacts reused in the validation package.
TraceabilityCritical requirements coveredGxP-critical requirements linked to design, risk, test evidence, and approval.
Customer scopeConfiguration risk closedCustomer-specific configurations, integrations, and workflows assessed and tested based on risk.
LifecycleRelease impact cycle timeTime from vendor release notice to documented impact assessment, testing decision, and approval.

What the white paper covers

  • What to expect from vendors: SDLC documentation, OQ evidence, traceability, quality/compliance support, and reference artifacts.
  • Where regulated companies remain accountable: intended use, vendor qualification, configuration, PQ, risk assessment, data integrity, and change control.
  • Advantages of outsourcing validation: domain expertise, reduced risk, cost savings, release management, automated testing, and continuous compliance maintenance.
  • How CSA changes the approach: less low-value documentation, more critical thinking, and more targeted automated testing.

Who should download it

  • Quality, Validation, and CSV/CSA leaders modernizing SaaS and cloud validation practices.
  • IT application owners managing releases, configurations, integrations, and vendor documentation.
  • Compliance and Data Integrity teams ensuring electronic records remain complete, attributable, legible, contemporaneous, original, and accurate.
  • Business process owners trying to move faster without weakening inspection readiness.
Contributors David Blewitt, VP of Cloud Compliance; Sandy Hedberg, Director of Quality Assurance and Regulatory Affairs; Hovsep Kirikian, VP of Strategy and Operations; Jim Macdonell, VP of Eastern Region, Medical Device Solutions; John Petrakis, VP of Cloud Assurance.

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