Commission Decision (EU) 2025/2371 appeared in the Official Journal on November 27, 2025 and started a six-month countdown. From May 28, 2026, four EUDAMED modules are mandatory rather than voluntary: actor registration, UDI and device registration, notified bodies and certificates, and market surveillance. Devices already placed on the market get until November 27, 2026 to finish their UDI and device registration entries.
The order of operations catches companies out. A manufacturer cannot register a device until it holds a Single Registration Number from actor registration, and a non-EU manufacturer needs its authorised representative registered as well. Basic UDI-DI and UDI-DI codes come from an issuing entity before any of that data can be uploaded. Each step has its own queue, so a company that starts in May 2026 will not finish in May 2026.