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BSI Request — Marketing Material, Website and IFU Corrections

Communication Reference​

FieldValue
SubjectFollow-up to BSI management call — 23 March 2026
BSI Request DateApril 2026
BSI ContactRisk and Compliance Team, BSI
Legit Health ContactSaray Ugidos, Quality and Regulatory Affairs Manager
Response Date27 April 2026
Related QMS ProceduresGP-001 (Control of documents), GP-023 (Change control management)

Background​

During a call held on 23 March 2026 between AI Labs Group S.L. (Legit Health) and BSI's management team, BSI identified that certain public-facing communications on the Legit Health website and in IFU documentation contained inaccurate statements regarding the device's conformity assessment status.

Specifically, certain website content incorrectly described the device as "Certified as a Class IIb medical device under the EU Medical Device Regulation (MDR 2017/745)", when in fact:

  • The device currently holds a Class I self-declaration under the EU Medical Device Directive (MDD 93/42/EEC), valid through 2028.
  • The MDR Class IIb conformity assessment is in progress with BSI as the Notified Body but has not yet been completed or certified.

Additionally, the EU IFU MDR (draft version v1.1.0.0) — which is part of the ongoing MDR Class IIb submission — was inadvertently accessible via the IFU link on the public website, when only the current MDD IFU should have been publicly available.


BSI Requested Actions​

BSI's Risk and Compliance team requested the following priority actions:

  1. Review and correct all public-facing communications to ensure strict alignment with the device conformity assessment status.
  2. Remove or amend any statements implying the device is already certified as Class IIb under the EU Medical Device Regulation (MDR 2017/745).
  3. Provide evidence to BSI that the above corrections have been completed.

Actions Taken​

All corrective actions were completed on 20 March 2026 — prior to the receipt of the formal written request from BSI — following an internal review triggered by the 23 March 2026 call preparation. The corrections were implemented by Taig Mac Carthy (Co-Founder & CEO) and verified by the quality team.

Action 1 — Regulatory Status Claims Corrected Across All Public-Facing Content​

Commit: e6a3ced66 — "Fix typo in regulatory status claims across website" — 20 March 2026

Scope: 21 files across all 4 website locales (EN, ES, DE, FR), including press releases, the public health system page, blog content, and SEO structured data.

Changes made:

LocationBefore (Incorrect)After (Correct)
Public health system page"Certified as a Class IIb medical device under the EU Medical Device Regulation (MDR 2017/745)""Currently transitioning to Class IIb under the EU Medical Device Regulation (MDR 2017/745), with the certification process under review by our Notified Body (BSI)"
Public health system page"This dual certification, particularly the higher-risk Class IIb designation...""This regulatory pathway, particularly the pursuit of the higher-risk Class IIb designation under MDR..."
Public health system pageTip box stating "The formal publication of the MDR Class IIb certificate is pending..."Removed entirely
SEO structured data"CE Mark Class IIb Medical Device""CE Mark Medical Device (MDD)"
Press releases (EN, ES, DE, FR)Various references implying Class IIb certificationCorrected to reflect current MDD Class I status
Website structured dataClass IIb referenceCorrected to MDD

Action 2 — Unsubstantiated Performance Claims and Diagnostic Language Removed​

Commit: 82b66349f — "Remove unsubstantiated performance claims and diagnostic language from website" — 20 March 2026

Scope: 95 files across all 4 website locales (EN, ES, DE, FR), including blog posts, press releases, homepage, footer, and i18n configuration files.

Changes made:

CategoryBefore (Incorrect)After (Correct)
Performance numbersSpecific accuracy percentages (93.23%, 94%, etc.)Removed — not appropriate for promotional material
Diagnostic language"diagnoses/detects [conditions]""supports the clinical assessment of"
Condition count"232 skin conditions""a wide range of skin conditions"
Promotional language"revolutionary""advanced"
Unsubstantiated claims"clinically proven""supported by published clinical evidence"
Patient empowerment claims"triples the empowerment""enhances the autonomy"
Homepage tagline & footerUpdated across all localesAligned with CDSS intended purpose

Action 3 — Promotional Language Aligned with CDSS Intended Purpose​

Commit: 777353f26 — "Align promotional content language with CDSS intended purpose across website" — 20 March 2026

Scope: 11 files — specific blog posts and pages where language needed further refinement to use precise clinical decision support terminology.

Changes made:

  • Replaced absolute comparative claims with specific, evidence-based descriptions
  • Harmonised language across EN/ES/DE/FR locales
  • Ensured all public-facing content accurately reflects the device's intended purpose as a Clinical Decision Support System (CDSS)

Action 4 — IFU Link Corrected​

The public website IFU link (https://apidocs.legit.health/) now serves exclusively the MDD IFU (Class I), which is the currently valid Instructions for Use for the device on the market. The draft EU IFU MDR (v1.1.0.0) is no longer publicly accessible and is maintained internally within the QMS as part of the ongoing MDR Class IIb submission to BSI.


Current State — Evidence of Compliance​

Website (https://legit.health/)​

Page / ElementCurrent ContentStatus
HomepageNo Class IIb claims. CE Mark logo references MDD.✅
About page"medical device with European CE marking" — no class or regulation specified beyond CE marking and ISO 13485✅
Canfield comparison"certified as a medical device" — refers to ISO 13485 compliance, no Class IIb or MDR claims✅
Public health system page"Certified as a Class I medical device under MDD 93/42/EEC, with certification valid through 2028" + "Currently transitioning to Class IIb under MDR"✅
SEO structured data"CE Mark Medical Device (MDD)"✅
Footer (all locales)CDSS-appropriate language, no Class IIb claims✅
Blog posts (all locales)Performance claims removed, diagnostic language replaced with CDSS terminology✅
Press releases (all locales)Regulatory status corrected across EN, ES, DE, FR✅

IFU (https://apidocs.legit.health/)​

ElementCurrent ContentStatus
Device label"Risk Classification according to Council Directive 93/42/EEC (MDD): Class I"✅
CE marking reference"CE marking per Council Directive 93/42/EEC"✅
UDI(01)8437025550005(10)2.1(11)YYYYMMDD✅
EMDN codingZ12040192✅
GMDN coding65975✅
No MDR/Class IIb referencesConfirmed — no references to MDR 2017/745 or Class IIb✅

EU IFU MDR (draft v1.1.0.0)​

ElementStatus
Public accessibility❌ Not publicly accessible — removed from public website link
Internal QMS locationMaintained within the version-controlled QMS (Git repository)
PurposePart of the ongoing MDR Class IIb conformity assessment submission to BSI

Git Audit Trail​

All corrections are fully traceable in the Git version control system:

Commit HashDateAuthorDescription
e6a3ced6620 March 2026 00:43Taig Mac CarthyFix typo in regulatory status claims across website (21 files)
82b66349f20 March 2026 02:01Taig Mac CarthyRemove unsubstantiated performance claims and diagnostic language (95 files)
777353f2620 March 2026 12:35Taig Mac CarthyAlign promotional content language with CDSS intended purpose (11 files)

Preventive Measures​

To prevent recurrence of inaccurate public-facing claims:

  1. Marketing content review process: All public-facing content related to the device's regulatory status, classification, or performance claims must be reviewed and approved by the Quality Manager (JD-004) before publication, in accordance with GP-001 (Control of documents).

  2. Regulatory language guidelines: A set of approved regulatory statements has been established for use by marketing and communications personnel. Any deviation from these approved statements requires prior written approval from the Quality Manager.

  3. Periodic website audit: The quality team will conduct a quarterly review of all public-facing website content to verify alignment with the current conformity assessment status. This review will be documented as part of the quality planning process (GP-002).


Conclusion​

All three actions requested by BSI have been completed:

  1. ✅ All public-facing communications have been reviewed and corrected to ensure strict alignment with the device's current conformity assessment status (Class I under MDD 93/42/EEC).
  2. ✅ All statements implying the device is already certified as Class IIb under MDR 2017/745 have been removed or amended to accurately reflect the transitional status.
  3. ✅ This document, together with the Git audit trail, constitutes the evidence that the corrections have been completed.

Prepared by: Saray Ugidos, Quality and Regulatory Affairs Manager, AI Labs Group S.L.

Date: 27 April 2026

Previous
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Technical Review: Round 1
  • Communication Reference
  • Background
  • BSI Requested Actions
  • Actions Taken
    • Action 1 — Regulatory Status Claims Corrected Across All Public-Facing Content
    • Action 2 — Unsubstantiated Performance Claims and Diagnostic Language Removed
    • Action 3 — Promotional Language Aligned with CDSS Intended Purpose
    • Action 4 — IFU Link Corrected
  • Current State — Evidence of Compliance
    • Website (https://legit.health/)
    • IFU (https://apidocs.legit.health/)
    • EU IFU MDR (draft v1.1.0.0)
  • Git Audit Trail
  • Preventive Measures
  • Conclusion
All the information contained in this QMS is confidential. The recipient agrees not to transmit or reproduce the information, neither by himself nor by third parties, through whichever means, without obtaining the prior written permission of Legit.Health (AI Labs Group S.L.)