Skip to content

Annex 11 vs Part 11: clause-by-clause mapping

Pick a topic, or a clause on either side, and see its counterpart: where 21 CFR Part 11 and EU GMP Annex 11 match, where Annex 11 asks for more and where Part 11 does, and the evidence that satisfies both. Mark each row for your lab and print the gap list. Already sure of the Part 11 side? Run the Part 11 compliance checklist first, then use this map for the Annex 11 extras.

What this map is

21 CFR Part 11 is a US regulation: FDA's rules for electronic records and electronic signatures, in force since August 20, 1997. EU GMP Annex 11 is European Commission guidance on computerised systems, published in EudraLex Volume 4 to interpret the EU's GMP principles. A lab that works under FDA rules and supplies an EU medicinal-product client is read against both, and the two are written in different shapes: Part 11 is a list of controls, Annex 11 a life cycle from risk assessment to archiving.

This tool sets them side by side in 25 rows. Each row names the clauses on both sides, quotes the words that matter, says how the two relate, and lists the evidence that satisfies both at once. For each Part 11 control on its own, read the Part 11 requirements section by section; for Annex 11 on its own, and when a US firm has to meet it, read EU Annex 11 for US labs and device makers.

Which Annex 11

The map uses the January 2011 revision of Annex 11 (“Deadline for coming into operation: 30 June 2011”), still the version listed in EudraLex Volume 4 when we read it on 2026-10-22. A revision was consulted on in 2025: a draft revised Annex 11, a revised Chapter 4 and a new Annex 22 on artificial intelligence were open for comment from 7 July to 7 October 2025. The 2011 text remains the one in force.

Our mapping

The pairing of clauses is our own reading of the two texts, not an official crosswalk. Where a clause has no true counterpart, the row says so and names the nearest section on the other side.

How to use this map

  1. Pick a way in: a topic, a Part 11 section, an Annex 11 clause, or a relation such as “Annex 11 only”. The picks combine.
  2. Read the row: the cites on each side, the words of each clause, and what one asks beyond the other. Open “Where they meet” for the evidence that satisfies both.
  3. Mark the row for your lab: In place, Gap or Not for us, with a note naming the document on file or what is missing.
  4. Copy or print the gap list. It carries each gap's clauses, what to close and the evidence for both, with lines for the preparer and QA to sign.

Six words describe how the two texts relate in a row:

Both ask it
The two clauses ask the same thing; one set of evidence covers both.
Annex 11 asks more
Both cover it, and Annex 11 asks for more detail or more evidence.
Part 11 asks more
Both cover it, and Part 11 asks for more.
Each adds something
They overlap, and each asks for something the other does not.
Annex 11 only
Only Annex 11 has the clause. The Part 11 side shows the nearest section, if any.
Part 11 only
Only Part 11 has the section. The Annex 11 side shows the nearest clause, if any.

The whole map on one sheet

All 25 rows in reading order, Part 11 cites on the left and Annex 11 clauses on the right. The tool above holds the clause words and the evidence for each.

21 CFR Part 11 and EU GMP Annex 11, clause by clause (our mapping)
Requirement21 CFR Part 11Annex 11 (2011)How they relate
Validate the system§ 11.10(a)Principle, § 4.1, § 4.3, § 4.4, § 4.6, § 4.7Annex 11 asks more
Check data after a migrationNo counterpart (nearest § 11.10(a), § 11.10(c))§ 4.8Annex 11 only
Copies and printouts of records§ 11.10(b)§ 8.1, § 8.2Each adds something
Protect stored records for the retention period§ 11.10(c)§ 7.1Annex 11 asks more
Back up the data and prove it restoresNo counterpart (nearest § 11.10(c))§ 7.2Annex 11 only
Archive data you can still retrieve§ 11.10(c)§ 17Annex 11 asks more
Limit access to authorised people§ 11.10(d), § 11.10(g)§ 12.1, § 12.2, § 12.3Each adds something
Audit trail of changes and deletions§ 11.10(e)§ 9, § 12.4Each adds something
Enforce the order of steps§ 11.10(f)No counterpartPart 11 only
Check data coming into the system§ 11.10(h)§ 5, § 6Each adds something
Qualified people with defined duties§ 11.10(i)§ 2Each adds something
Change control and system documents§ 11.10(k)§ 10, § 4.2Each adds something
Extra controls for open systems§ 11.30No counterpart (nearest § 3.1, § 12.1)Part 11 only
What a signed record shows§ 11.50§ 14(c)Part 11 asks more
Signature locked to its record§ 11.70§ 14(b)Part 11 asks more
An e-signature counts as a handwritten one§ 11.10(j), § 11.100(c)§ 14(a)Part 11 asks more
One signature per person, identity verified§ 11.100(a), § 11.100(b)No counterpart (nearest § 12.3)Part 11 only
Two components to sign§ 11.200§ 12.1Part 11 asks more
Controls on IDs, passwords and tokens§ 11.300§ 12.1, § 12.3Part 11 asks more
Risk management across the life cycleNo counterpart§ 1Annex 11 only
Agreements with suppliers and service providersNo counterpart (nearest § 11.10(a), § 11.10(i))§ 3.1, § 3.2, § 3.3, § 3.4, § 4.5Annex 11 only
Periodic evaluation of each systemNo counterpart§ 11Annex 11 only
Report and assess every incidentNo counterpart (nearest § 11.300(d))§ 13Annex 11 only
Business continuity when the system is downNo counterpart§ 16Annex 11 only
Batch release by a Qualified PersonNo counterpart (nearest § 11.10(g))§ 15Annex 11 only

Both ask it: one set of evidence covers both. Asks more: both cover it, one asks for more. Each adds something: they overlap and each asks for something the other does not. Only: no counterpart; the nearest section is in brackets.

Worked example: a US contract lab and its first EU client

A 14-person US contract QC lab runs release and stability testing on a LIMS and a chromatography data system, both validated for Part 11. Its first EU client's quality agreement asks it to meet Annex 11 as well. The QA lead walks the 25 rows: 13 are in place, 3 do not apply (no migration planned, a closed system, and batch certification stays with the client's Qualified Person) and 9 are gaps.

The worked example's gap list
GapClausesWhat the lab foundEvidence to produce
Validate the systemAnnex 11 asks morePart 11: § 11.10(a)Annex 11: Principle, § 4.1, § 4.3, § 4.4, § 4.6, § 4.7Validation reports exist; no IT infrastructure qualification and no system inventory.Validation plan and report scoped by a written risk assessment; URS traced to test cases; infrastructure qualification record; system inventory; a test that shows the system flags an altered or invalid record.
Copies and printouts of recordsEach adds somethingPart 11: § 11.10(b)Annex 11: § 8.1, § 8.2No report that flags changed results on release data.A tested export of one complete record (data, metadata and audit trail) as a readable report and as an electronic file; for release records, a report that flags every changed entry.
Back up the data and prove it restoresAnnex 11 onlyPart 11: No counterpart (nearest § 11.10(c))Annex 11: § 7.2Restore tested once at OQ; no periodic restore test since.A back-up procedure, a restore test in validation, and periodic restore tests with their results on file.
Limit access to authorised peopleEach adds somethingPart 11: § 11.10(d), § 11.10(g)Annex 11: § 12.1, § 12.2, § 12.3Access changes made by IT ticket; not recorded in the system file.A role matrix with the rights of each role, a log of access granted, changed and removed with approvals, and a periodic access review.
Audit trail of changes and deletionsEach adds somethingPart 11: § 11.10(e)Annex 11: § 9, § 12.4Trail is on, but no reason is forced when a result is edited.A trail on create, modify and delete with a forced reason on GMP fields, kept with the record; a scheduled audit trail review with a signed record of each one.
Risk management across the life cycleAnnex 11 onlyPart 11: No counterpartAnnex 11: § 1Validation scope set by habit; no written risk assessment.A system risk assessment that sets the validation scope and the data integrity controls, revisited at each change and periodic evaluation.
Agreements with suppliers and service providersAnnex 11 onlyPart 11: No counterpart (nearest § 11.10(a), § 11.10(i))Annex 11: § 3.1, § 3.2, § 3.3, § 3.4, § 4.5No quality agreement with the LIMS hosting vendor.A quality agreement with each software vendor and host, a supplier assessment or audit report, and a documented review of the vendor's documentation against your URS.
Periodic evaluation of each systemAnnex 11 onlyPart 11: No counterpartAnnex 11: § 11No periodic review since go-live.A periodic review report per system that reads those inputs and ends in a decision: still valid, or what must change.
Business continuity when the system is downAnnex 11 onlyPart 11: No counterpartAnnex 11: § 16Fallback to paper worksheets not written down or tested.A written fallback for each critical system, a recovery time set by risk, and a dated test of the fallback.

6 of the 9 gaps sit where Annex 11 asks more than Part 11 or stands alone: risk assessment, supplier agreements, periodic evaluation, back-up restores, business continuity and the validation pack. The other 3 are rows where each text adds something and the lab had only the Part 11 half: a trail without a forced reason, access changes with no record, copies with no changed-data flag. None of the gaps is a signature row: a system validated for Part 11 signatures already covers the three lines of Annex 11 § 14. The cheapest first step is the risk assessment, because Annex 11 sizes the validation, the audit trail and the review cycle from it. A validation pack sized for a small lab holds most of the rest.

Where the two differ in kind

  • Regulation and guidance. Part 11 is codified US law and says “shall”. Annex 11 “provides guidance for the interpretation of the principles and guidelines of good manufacturing practice” and mostly says “should”.
  • Scope. Part 11 reaches electronic records kept under an FDA records rule or submitted to FDA (§ 11.1(b)); check whether it applies to a record. Annex 11 applies to every computerised system used in GMP-regulated activities.
  • Risk. Annex 11 opens with risk management (§ 1) and sizes validation by it. Part 11's text has no risk clause; FDA's 2003 guidance supplies one, asking for “a justified and documented risk assessment”, the same words Annex 11 uses.
  • Signatures. Part 11 spends five sections on electronic signatures; Annex 11 gives them three lines in § 14. A system that passes the signature manifestation check already meets § 14(c).
  • After go-live. Annex 11 keeps going where Part 11 stops: supplier agreements, periodic evaluation, incident management and business continuity. For hosted systems, see Part 11 for cloud and SaaS systems.

Common misreading

“Annex 11 requires an audit trail on every system.” The 2011 text says “Consideration should be given, based on a risk assessment”. And the reverse slip: “regularly reviewed” comes from Annex 11 § 9; § 11.10(e) requires the trail, not a review cadence. The audit trail review checklist builds a review that serves both.

Where the rule says so