GxP / Guide 2

Part 11 and Annex 11, requirement by requirement

What 21 CFR Part 11 and EU GMP Annex 11 actually require, what the 2025 Annex 11 draft adds, and which technical control answers each requirement.

Most IT people meet Part 11 and Annex 11 as a list of demands from a validation lead. Reading the text itself is quicker than you'd think (Part 11 is two pages of rules), and knowing which clause a control answers makes design reviews and audits far shorter. This guide goes through both, then maps them to controls on Azure, AWS and Microsoft 365.

21 CFR Part 11 in one page

Part 11 applies to electronic records that a predicate rule requires, and to electronic signatures used in place of handwritten ones. Its main sections:

SectionRequirementWho usually owns it
11.10(a)Validation: accuracy, reliability, consistent intended performance, and the ability to spot invalid or altered recordsSystem owner, validation
11.10(b)Accurate and complete copies, in human-readable and electronic form, for inspectionApplication
11.10(c)Protect records so they can be retrieved accurately and readily for the whole retention periodIT: backup, archive, storage
11.10(d)Limit system access to authorized individualsIT and application: identity, roles
11.10(e)Secure, computer-generated, time-stamped audit trails of entries and actions that create, modify or delete records. Changes must not obscure what was there before. Keep the audit trail as long as the record.Application, plus IT for platform logs
11.10(f), (g), (h)Operational checks (enforced sequence of steps), authority checks (only authorized people can sign, change or use), device checks (valid source of input)Application
11.10(i)People who build, maintain or use the system are trained and qualifiedEveryone, including IT and cloud admins
11.10(j)Written policy holding people accountable for actions under their electronic signatureQuality
11.10(k)Control over system documentation, with change control and an audit trail of document changesQuality, IT
11.30Open systems (where you don't control access): add encryption and digital signature standards as neededIT
11.50, 11.70Signed records show printed name, date and time, and meaning (approved, reviewed); signatures are linked to their records so they can't be copied or removedApplication
11.100Each electronic signature is unique to one person, never reused or reassigned; identity verified before issue; a one-time certification letter to FDAQuality, HR, IT identity
11.200Non-biometric signatures use at least two components (such as ID and password); the first signing in a session uses both, later signings at least oneApplication, identity
11.300Controls on IDs and passwords: unique, periodically checked and revised, lost credentials handled, attempts at misuse detected and reported, tokens testedIT identity

How FDA enforces it

FDA's 2003 guidance Part 11, Electronic Records; Electronic Signatures — Scope and Application still shapes how Part 11 is applied. It says FDA interprets the scope narrowly and exercises enforcement discretion on validation, audit trails, record retention, record copying and legacy systems, as long as the predicate rules are met and decisions are justified by a documented risk assessment. In practice that means: audit trails and validation are still expected for anything that matters, but the depth is yours to justify. It does not relax access control, signature or record integrity expectations.

Annex 11 (2011)

Annex 11 is shorter than Part 11 but broader: it covers the whole life cycle of a computerised system used in GMP, not only records and signatures. Its seventeen sections:

SectionTopicWhat it asks of IT
1Risk managementControls sized to risk, across the life cycle
2PersonnelQualified people with defined responsibilities, IT included
3Suppliers and service providersFormal agreements; audits based on risk; supplier documentation reviewed. This is where cloud providers are covered.
4ValidationLife cycle validation, inventory of systems, requirements traceability, infrastructure qualified
5, 6Data, accuracy checksChecks on data exchanged between systems; checks on critical manual entries
7Data storageData secured against damage; regular backups; backup integrity and restore checked during validation and monitored periodically
8PrintoutsClear printed copies; show if data changed since entry
9Audit trailsBased on risk, record GMP-relevant changes and deletions with the reason; audit trails available, readable and regularly reviewed
10Change and configuration managementChanges made in a controlled way under a defined procedure
11Periodic evaluationSystems reviewed periodically to confirm they remain valid
12SecurityPhysical and logical access controls; creation, change and removal of access recorded
13Incident managementIncidents reported, assessed and root causes found
14Electronic signatureSame effect as handwritten; permanently linked; time and date
15Batch releaseOnly qualified persons can certify release, identified and recorded
16Business continuityArrangements to keep critical processes going when systems fail, tested
17ArchivingArchived data checked for accessibility, readability and integrity, especially after system changes

The 2025 Annex 11 draft

The draft revision published in July 2025 grows Annex 11 from about five pages to about nineteen. When it becomes final, expect these to matter most to IT:

  • Cloud and service providers: much more detail on what agreements must cover, including oversight, audit and inspection support, communication of quality and security issues, and exit arrangements that keep you in control of your data.
  • Identity and access management: unique personal accounts (no shared accounts with write access), multi-factor authentication for remote access to critical systems, lockout, session time-outs, logged and reviewable access changes, and segregation of duties.
  • Audit trail review: who, what, when and why for changes, and risk-based review of audit trails before data is used for decisions such as batch release.
  • Security as a GMP topic: patching, vulnerability management, network segmentation and security testing written into the annex, not left to IT policy.
  • Backup, archive and periodic review: backups separated from the live system and restore-tested; archives protected and verified; a defined list of items every periodic review covers.

The companion draft Annex 22 restricts AI in critical GMP uses to static, deterministic models, and excludes generative AI and large language models from critical applications. If you're planning AI for GxP work, read it now.

Mapping requirements to cloud controls

The table below is the one to bring to a design review. It covers the infrastructure layer only: the application still has to meet its own requirements.

RequirementAzureAWSMicrosoft 365
Limit access (11.10(d), A11 §12)Entra ID groups, Azure RBAC, PIM, Conditional AccessIAM Identity Center, permission sets, SCPsSharePoint groups, sensitivity labels
ID and password controls (11.300)Entra ID password and lockout policies, MFA, sign-in logsIdentity Center with external IdP and MFAEntra ID
Platform audit trail (11.10(e), A11 §9)Activity log and resource logs to Log Analytics; immutable storageCloudTrail with log file validation; S3 Object LockPurview Audit
Protect and retrieve records (11.10(c), A11 §7, §17)Azure Backup with immutable vaults; blob immutabilityAWS Backup with Vault Lock; S3 Object LockRetention labels, records management
Change control (11.10(k), A11 §10)IaC pipelines with approvals; Azure Policy; deployment stacksCloudFormation or Terraform pipelines; AWS Config; drift detectionChange-controlled site templates
Business continuity (A11 §16)Azure Site Recovery, cross-region restoreElastic Disaster Recovery, cross-region copiesMicrosoft-operated resilience; your own exit and export plan
Continuous compliance checksAzure Policy, Defender for CloudAWS Config conformance pack for 21 CFR Part 11Purview Compliance Manager (has a Part 11 regulation template)

A clean compliance dashboard is supporting evidence, not proof. AWS says its Part 11 conformance pack is a sample template, and the same is true of any policy set: most Part 11 and Annex 11 requirements are met by the application and by your procedures.