What is FDA 21 CFR Part 11? Complete 2026 Guide

If you're moving paper processes to digital systems in a regulated industry such as pharmaceuticals or biotechnology, you've probably heard of FDA 21 CFR Part 11. Maybe you've been told your software needs to be "Part 11 compliant," or you're concerned about what happens during an FDA inspection.

At its core, the regulation is straightforward: if you're FDA-regulated and use electronic records or signatures for required activities, those systems must have specific controls to ensure they are as trustworthy as paper and ink. The challenge comes in determining which documents actually need those controls and how to identify electronic software that helps you meet those requirements.

This guide cuts through the confusion. You'll learn exactly when Part 11 applies, what the FDA looks for during inspections, and how to build electronic workflows you can defend with confidence.

What is 21 CFR Part 11?

FDA 21 CFR Part 11 establishes the criteria for electronic records and electronic signatures to be considered trustworthy, reliable, and legally equivalent to paper records and handwritten signatures in FDA-regulated industries.

Here are three key things to understand:

1. Part 11 doesn't require you to go digital. If you're happy with paper, you can keep using it
2. Not every electronic system in your organization falls under Part 11. Only systems that create, modify, or manage records required by FDA regulations
3. To meet part 11 fully, you need an electronic records and e-signature tool, documented procedures, training, and system validation

Key requirements for electronic records under 21 CFR Part 11

FDA 21 CFR Part 11 sets out the criteria needed to ensure electronic records and electronic signatures are trustworthy, reliable, and equivalent to paper and handwritten signatures. The requirements include:

1. System validation

System validation means proving and documenting that a computerized system consistently works as intended for its specific use. In practice, this involves defining requirements, testing against those requirements, resolving any issues, and keeping clear records of the entire process. 

A risk-based approach is common, with higher risk processes requiring more rigorous validation. Without validation, inspectors may question whether data produced by the system is reliable.

2. Electronic records controls

Electronic records must be protected so they remain complete, accurate, and secure for as long as they are needed. Key expectations include:

• Access controls: Only authorized users should be able to view or change records, with individual user accounts required
• Record integrity: Finalized records must be protected from unauthorized or undetected changes
• Version control: Changes must be traceable so it is clear who changed what and when
• Retention and retrieval: Records must remain readable and retrievable for the full retention period, including during FDA inspections

These controls ensure records cannot be altered, lost, or misused without detection.

3. Electronic signature requirements

Electronic signatures used in regulated activities must be uniquely tied to a specific individual and clearly indicate their intent. Part 11 requires:

• Unique user identity for each signer
• Authentication before signing
• Signature meaning that clearly shows why the person signed
• Permanent linkage between the signature and the record

This ensures accountability and prevents signatures from being copied, reassigned, or denied later.

4. Audit trails

Audit trails are secure, computer-generated records that automatically track key actions in the system. They should record who acted, what changed, when it happened, and, where relevant, the previous and new values. Audit trails must be automatic, tamper-evident, retained as long as the record exists, and available for FDA review. They are a primary indicator of data integrity during inspections.

5. Controls of closed systems vs open systems

A closed system is one where access is controlled by the organization responsible for the content of the electronic records. Most internal systems fall into this category. 

An open system is one where access is not fully controlled by the organization, such as systems that allow external access or transmission over public networks.

Open systems require additional security controls to ensure record authenticity, integrity, and confidentiality. In practice, many modern cloud systems are treated as closed systems when access controls are properly implemented and managed.

6. Copies and record retrieval

Part 11 requires that electronic records can be accurately and readily retrieved throughout their retention period. This includes the ability to generate human-readable copies for FDA inspection.

Inspectors must be able to:

• Access records promptly
• Verify their completeness and authenticity
• Review audit trails associated with the records

Who must comply with 21 CFR Part 11?

Simply put: Anyone in FDA-regulated industries, such as:

• Pharmaceutical and biopharmaceutical companies
• Medical device manufacturers
• Biotechnology companies
• Clinical research organizations and trial sponsors
• Food and beverage manufacturers
• Dietary supplement manufacturers

However, just because you’re in any of these industries does not mean every electronic file you create falls under Part 11. It applies only when FDA-required records are created, signed, or maintained electronically.

Think of it this way:

Part 11 applies when all of the following are true:

1. A predicate rule requires the record

Predicate rules are other FDA regulations (not Part 11 itself) that require you to create and maintain records, such as:

• 21 CFR Part 211 – cGMP for finished pharmaceuticals
• 21 CFR Part 820 – Quality System Regulation for medical devices
• 21 CFR Part 58 – GLP for nonclinical studies
• 21 CFR Part 312 – IND applications
• Other GxP regulations

2. The record is kept in electronic form, or an electronic signature replaces a handwritten signature

If the electronic version is the official record, or you use e-signatures instead of ink signatures, Part 11 applies. Even if the record is later printed, any electronic step that is relied upon for compliance (like approving a batch record electronically) must meet Part 11 requirements. 

If paper remains the official, controlled record and the electronic version is only a convenience copy, Part 11 normally does not apply.

3. The electronic record is used to meet FDA requirements

For example, electronic batch records, training records, CAPAs, validation documents, or clinical documentation that you rely on to show compliance. 

How Docupilot helps your company achieve 21 CFR Part 11 compliance

A key part of Part 11 compliance is having an electronic records and e-signature system that meets regulatory requirements. While many tools claim to be Part 11 compliant, there is no formal certification like HIPAA. Instead, you can evaluate a tool by ensuring it has the features that help your organization maintain Part 11-compliant workflows.

Docupilot is one such tool. It’s a document automation and e-signature platform that lets you create documents automatically from templates using data from spreadsheets, forms, or CRM systems. For regulated industries, Docupilot can automate the creation, approval, and distribution of repetitive documents like batch records, SOP approvals, or training records while supporting your Part 11 compliance program.

Here’s how Docupilot supports 21 CFR Part 11 compliance.

Take the next step towards Part 11 compliance

FDA 21 CFR Part 11 compliance does not have to be complicated. Once you understand what the regulation requires and have the right systems in place, building compliant electronic workflows becomes far more manageable.

Docupilot gives you the technical controls needed to support your Part 11 program, including secure electronic signatures, automatic audit trails, controlled access, version control, and protected record storage. Together, these features help you create reliable, traceable records you can confidently present during an FDA inspection.

Ready to modernize your document workflows while staying compliant? Start your free 30-day Docupilot trial today and see how easy it can be to manage electronic records with confidence.