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21 CFR Part 11 compliance checklist

Every requirement of 21 CFR Part 11, from the § 11.10 controls to the § 11.300 password rules, as one line each with its cite. Set the system's profile, mark each line, and print the gap list for your next validation or audit meeting.

What it checks

30 lines covering Subpart B (§§ 11.10, 11.30, 11.50, 11.70) and Subpart C (§§ 11.100, 11.200, 11.300). Each line keeps the rule's operative words and adds the evidence an inspector usually asks to see. The profile drops the lines a system cannot owe: § 11.30 for a closed system, the token lines when nobody uses tokens, the password lines for biometric signing, and every signature line for a system nobody signs in.

The checklist assumes Part 11 applies. It reaches only records a predicate rule requires, or records you submit to FDA, kept in electronic form; paper printouts that meet the predicate rule and are the records you rely on do not trigger it. If you are not sure, run the Part 11 applicability checker first, and the open vs closed system check if a vendor hosts the system.

How to use this checklist

  1. 01Pick one system. Part 11 is met system by system, so a LIMS, an ELN and a document control tool each get their own sheet.
  2. 02Set the profile. Open or closed decides whether § 11.30 is in play; how people sign decides which § 11.200 and § 11.300 lines count.
  3. 03Mark every line In place, Partly, Not yet or Not applicable, and write the evidence you would hand an inspector in the note.
  4. 04Use Not applicable only where the rule allows it, such as the "as appropriate" lines in § 11.10(f) and (h), and say why in the note.
  5. 05Print or copy the result. The gap list puts Not yet first; each gap becomes a change control, a CAPA or an SOP to write.

For the reasoning behind each line, read Part 11 requirements, section by section. Two lines have their own tools: the signature manifestation check for § 11.50, and the audit trail review checklist for what sits behind § 11.10(e).

Worked example: a small QC lab

The tool opens on this example: a small QC lab's chromatography data system, a closed system on the lab's own server, eight named users, signing with a user ID and password. Four lines fall out of scope from the profile (§ 11.30, § 11.200(b), § 11.300(c) and (e)), and the lab marked § 11.10(h) Not applicable because each instrument has one acquisition PC. Result: 13 of 25 in place. 26 of 26 lines marked: 13 in place, 9 partly, 3 not yet, 1 not applicable.

The example lab's gap list
CiteStatusWhat the lab found
§ 11.10(j)Not yetNo signed e-signature accountability policy.
§ 11.100(b)Not yetNo record of an identity check before accounts were issued.
§ 11.100(c)Not yetNo Non-Repudiation Letter on file.
§ 11.10(a)PartlyVendor IQ/OQ on file; PQ for our own methods not written yet.
§ 11.10(c)PartlyNightly backup runs; a restore has never been tested.
§ 11.10(e)PartlyArchive SOP names the results but not the audit trail.
§ 11.10(g)PartlyTwo senior analysts also hold the admin role.
§ 11.10(i)PartlyUser training on file; none for the IT contractor who patches the server.
§ 11.10(k)(2)PartlyConfig changes logged; manual revisions not tied to change control.
§ 11.50(b)PartlyCustom report template prints name and date but drops the meaning.
§ 11.200(a)(2)–(3)PartlyAdmins can set a user's password without the user knowing.
§ 11.300(d)PartlyLockout after 3 failed tries; nobody is alerted.

12 gaps, Not yet first. Scroll sideways on a phone for the last column.

The three Not yet lines cost the least to close: a one-page accountability policy every signer signs, an identity check filed for each of the eight accounts, and the company's Non-Repudiation Letter. The biggest Partly is § 11.10(a); the lab scoped the missing performance testing with the CSA validation scope planner and logged the contractor's training on a training record.

What the 2003 guidance changes, and what it does not

Lines marked “enforcement discretion area” sit in the four areas FDA's 2003 Scope and Application guidance narrowed: validation, audit trail, record retention and record copying (§ 11.10(a), (b), (c), (e) and (k)(2)). FDA wrote that it does “not intend to take enforcement action to enforce compliance with the validation, audit trail, record retention, and record copying requirements of part 11 as explained in this guidance.”

Common misreading

That is not a pass on those lines. The same guidance says FDA “will enforce all predicate rule requirements, including predicate rule record and recordkeeping requirements”, and predicate rules carry their own versions: § 211.68(b) for drug CGMP computer controls and backups, § 58.130(e) for GLP data changes that must not obscure the original entry. Part 11 sets no retention period of its own; the predicate rule does. The signature sections, §§ 11.50 to 11.300, stay fully enforced.

Four lines teams misread

  • § 11.200(a)(1)Part 11 does not require biometrics, tokens or multi-factor login. "An identification code and password" meets the two-component rule; digital signatures and encryption appear only as additional measures for open systems in § 11.30.
  • § 11.50(a)The time on a signature does not have to be the signer's local time. The 2003 guidance says FDA does not expect it, and that your documentation should explain the time zone reference.
  • § 11.100(c)The certification letter is yours, not your vendor's. The rule puts it on "Persons using electronic signatures", and FDA accepts an individual or a company-wide letter.
  • § 11.10(i), (j)A vendor can supply the audit trail and the signing dialog, but training and the accountability policy are always your lines to close.

Selling to the EU as well? Annex 11 asks for things Part 11 does not, such as periodic evaluation and business continuity; the Annex 11 vs Part 11 mapping lines them up clause by clause.

Where the rule says so

The rule text and the guidance this checklist is built from, each read on the date shown.

  1. 21 CFR Part 11, Electronic Records; Electronic Signatures (eCFR), National Archives and FDAread 2026-10-22
  2. Part 11, Electronic Records; Electronic Signatures: Scope and Application (guidance, 2003), FDAread 2026-10-22
  3. Letters of Non-Repudiation Agreement, FDAread 2026-10-22
  4. 21 CFR Part 211, CGMP for Finished Pharmaceuticals (eCFR), National Archives and FDAread 2026-10-22
  5. 21 CFR Part 58, Good Laboratory Practice for Nonclinical Laboratory Studies (eCFR), National Archives and FDAread 2026-10-22