FDA posts draft guidance for robotically-assisted surgical devices
25 Sep 2026 (ET): The FDA published a Federal Register notice opening draft guidance on what makers should put in premarket submissions for robotically-assisted surgical devices (RASDs). Comments are due by Nov 24, 2026. The draft is not final and not for implementation yet.
HEALTH desk — a surgical robot is a console, a set of arms, instruments, and software, sitting on a hospital network while a surgeon operates. A public FDA checklist matters because the maker has to show, before a clearance, how long the instrument takes to follow the hand, how the system behaves if that network is already compromised, and how any artificial-intelligence feature was tested. The notice says this draft is not final and is not for use yet. Comments through November 24 are the chance to argue about that checklist before the agency starts a final version.
What the notice says the draft is. The summary says the FDA is announcing the availability of that draft guidance. It says the draft provides draft recommendations for premarket submissions for robotically-assisted surgical devices, shortened to RASDs. A premarket submission is the package a maker sends before the agency clears or approves a device for sale. That gloss is this desk’s. The same summary says this draft guidance is not final nor is it for implementation at this time. Not final, and not for implementation, are the notice’s words. They are the limit on everything else in this filing.
Where it sits in the Register, and two clocks on the same document. The citation is 91 FR 60967. The pages are 60967 through 60968. Volume 91, number 185, is Friday, September 25, 2026. The publication date on the API record is 2026-09-25. The notice’s billing line says it was filed 9-24-26 at 8:45 a.m. Filed is the line at the bottom of the notice. Published is the Friday date at the top. Do not collapse 24 Sep and 25 Sep. The signatory is Grace R. Graham, Deputy Commissioner for Policy, Legislation, and International Affairs. The billing code is 4164-01-P.
What the notice says a RASD is. In the background section, a robotically-assisted surgical device is a teleoperated, software-controlled system. It integrates robotic technologies and subassemblies. It is designed to assist qualified practitioners in precisely positioning and controlling multiple surgical instruments, so they can safely and effectively perform open, minimally invasive, or endoluminal procedures. Teleoperated, here, means a person runs the machine from a console. The machine is not choosing the operation on its own. Software-controlled means code sits between the hand and the instrument. Those glosses are this desk’s. Multiple surgical instruments is the notice’s phrase.
The draft document uses a different count, and this desk does not collapse it. The draft this desk read is the file at fda.gov/media/194987/download. The cover says “Document issued on September 25, 2026.” The document number on the additional-copies line is GUI01500081. The cover says the draft is being distributed for comment purposes only. Its definition says the systems are designed to assist qualified practitioners in precisely positioning and controlling one or more surgical instruments. One or more is the draft’s phrase. Multiple is the notice’s. AHA’s same-day story also says one or more. Do not file those as one sentence.
Who is in charge, in the draft’s words. The draft says RASDs are used under direct control or supervision of a qualified practitioner. It says they use a leader/follower control system architecture and may contain some level of automated functions to enhance and augment user capabilities. Leader/follower, here, means the surgeon’s console leads and the arms follow. An automated function is a helper inside that setup, not a robot that operates alone. Those glosses are this desk’s. The draft’s scope section says this guidance does not address remotely teleoperated RASDs, or autonomous robots that perform significant aspects of operative procedures independent of qualified practitioners. Remote, in that sentence, means the console is not in the same operating room as the patient-side unit. Autonomous, in that sentence, means the machine does major parts of the operation without the practitioner. Those glosses are this desk’s. The draft says some of its recommendations may still be relevant to those machines, and it points makers of out-of-scope devices to the Q-Submission Program for feedback. Pre-operative planning systems and stereotaxic navigation systems are also outside the scope. Stereotaxic, here, means a system that tracks instruments against a map of the patient’s anatomy. That gloss is this desk’s.
The three pieces the draft says these systems generally have. An operator console, which the draft also calls a surgeon console, is where the practitioner views the surgical field and controls the instruments and cameras. A bedside, or patient, subassembly — a cart or a pedestal is the example — has working arms that move cameras, instruments, accessories, or third-party devices inside the patient, plus safety features a bedside assistant can reach. An operating-room staff subassembly, the example is a tower, holds supporting hardware and software, such as an electrosurgical unit, suction and irrigation pumps, a second screen, an insufflation unit, and the light for the endoscope. Insufflation is the gas that makes room in the abdomen for a minimally invasive case. An endoscope is the camera tube. Those glosses are this desk’s. The draft says a footnote: systems with a different physical layout are still in scope if they meet the definition.
What a submission should describe, still the draft’s recommendation. For every RASD submission, the maker should give a clear device description of all the major functional parts, starting with the whole system, then the subassemblies and other components. The list includes the entire setup, how it works, a kinematic diagram, a connections diagram that includes external services and servers, how data moves, and physical dimensions. Kinematic, here, means how the arms are allowed to move. That gloss is this desk’s. The bedside section of that list includes the working arms, an emergency stop, and how the team gets to the patient in an emergency. The draft says the word should, in an FDA guidance, means suggested or recommended, not required.
The delay the draft says to measure. Total system latency, in the draft, is the cumulative delay from the surgeon’s hand input at the operator console to instrument motion, and from instrument motion to the matching picture on the main display. The draft says that delay matters because it affects whether the operator can move precisely and safely in real time. The recommendation is that testing show the delay between the hand control, the instrument, and the picture stays inside limits the maker defines and can justify clinically. The draft says to measure it under representative and worst-case conditions, including the heaviest processing load and a typical clinical setup, and to cover straight moves, turns, and opening and closing the instrument. It says FDA recommends testing a minimum of three RASDs. Three is the draft’s minimum. If a maker proposes fewer, the draft says to explain why that number still shows consistent performance. This desk did not time a console.
Security, in the draft’s cybersecurity section. The draft says these systems contain software and may connect to a network, which widens the ways an attack could reach the device. It says a failure of cybersecurity can compromise how the device works, knock it offline, damage or hide medical or personal data, or expose other devices on the network, and that those failures may injure a patient. If the device meets the statute’s definition of a cyber device, the submission must meet the cybersecurity requirements in section 524B of the Federal Food, Drug, and Cosmetic Act. On top of FDA’s existing cybersecurity guidance, the draft says a RASD submission should name the assets, threats, and vulnerabilities, judge how exploitable they are, set risk levels, and describe mitigations. The assessment, including penetration testing, should cover every network piece that talks to the system, the accessories, and the compatible devices, in setup, ordinary use, and maintenance. Penetration testing means someone tries to break in on purpose, in a test. That gloss is this desk’s. The draft says that map should include servers, databases, and cloud services, and the public and private networks used for data, remote access, teleoperation, or updates. The example in the draft is a simulation in which the RASD is communicating with a hospital network that has already been compromised.
Artificial intelligence, if the machine has it, is an extra feature in the draft, not a requirement that every robot include it. The draft’s list of additional features includes eye tracking, haptics, extra imaging such as X-ray or MRI, and built-in artificial intelligence or machine learning. The examples it gives are image segmentation, image augmentation, identifying a critical structure, and instrument tracking. Haptics means a force or touch signal back to the surgeon. Segmentation means software that marks regions in an image. Those glosses are this desk’s. The draft says these features can help and can also add risk, and that the maker should do a risk assessment and test each one in line with that risk. If the system includes AI or machine-learning features, the draft says to discuss the plan with FDA through the Q-Submission Program. It points to a separate draft guidance on artificial-intelligence-enabled device software functions for data, the model description, performance checks, and transparency, and to the guidance on a predetermined change-control plan if the maker expects to modify that software after authorization. Those are other documents. This filing does not summarize them.
What else the notice says the draft covers, without turning the table into this story. The notice says the draft gives recommendations on non-clinical and clinical testing and on what goes in the premarket submission, so review is more consistent and more efficient. It says the draft, when finalized, will represent FDA’s current thinking. It does not establish rights for any person and is not binding on FDA or the public. A maker can use another approach if it meets the applicable statutes and regulations. The notice says that as FDA writes the final guidance it will consider comments on costs or cost savings, relevant for Executive Order 14192. It says the guidance contains no new collection of information and points at collections the Office of Management and Budget has already approved, including premarket notification, premarket approval, investigational device exemptions, and De Novo classification. This desk did not open those older collections.
Who to call, kept as two numbers. The notice’s contact is Erica Takai, Center for Devices and Radiological Health, 301-796-6353. The draft’s questions line is the Division of General Surgery Devices, 301-796-6970. Those are two numbers on two documents. Do not collapse them. Comments go to regulations.gov, or on paper to the Dockets Management Staff, 5630 Fishers Lane, Room 1061, Rockville, MD 20852, 240-402-7500. A request for one hard copy of the draft goes to the Office of Policy at the Center for Devices and Radiological Health, 10903 New Hampshire Ave., Building 66, Room 5441, Silver Spring, MD 20993-0002, with a self-addressed label. The draft says an email request for a copy can go to CDRH-Guidance@fda.hhs.gov, using document number GUI01500081. The notice’s email address was masked on the page this desk read. This desk does not print a guessed address for that line.
The comment deadline, and a second date on the API record. The notice says submit electronic or written comments by November 24, 2026, so the agency considers them before it begins work on the final version. The API field comments_close_on is 2026-11-24. The same API record’s regulations.gov document, id FDA-2026-N-9505-0001, lists comment_end_date 2026-11-25. November 24 is the notice. November 25 is that document record. Do not collapse them. The notice also says comments on any guidance may be submitted at any time under 21 CFR 10.115(g)(5). The November date is the one tied to being considered before work on the final version starts.
What this desk could and could not load besides the notice and the draft. The American Hospital Association’s headline, stamped Sep 25, 2026, 02:20 PM, says the FDA released draft guidance Sept. 24 with recommendations on non-clinical testing, clinical data, and labeling for certain robotically-assisted surgical devices. Sept. 24 is AHA’s verb for the release. The draft’s cover says issued on September 25, 2026. The notice was filed 9-24-26 and published September 25. Do not collapse those. AHA’s definition uses one or more surgical instruments, matching the draft, and says comments are due by Nov. 24 before a final version. This desk’s request for the MobiHealthNews story at the address in the sources hit a Cloudflare challenge page, so this write-up does not quote a MobiHealthNews sentence. This desk’s request for the FDA guidance landing page returned the words “Not found,” so this write-up does not quote a landing-page body. A later direct request for the draft PDF was redirected to an FDA abuse-detection page. The draft sentences above are from the text this desk had already read.
What the card shows. The card is a licensed photograph of a da Vinci Xi patient-side cart, the bedside unit of a robotically-assisted surgical system, standing in an operating room. The boom is labeled da Vinci Xi. Four arms hang from it, numbered. A supply cart and a sink are in the room. Those labels are on the machine. No date is printed on the card. The photograph is Alvarogarciamd’s, on Wikimedia Commons, under the Creative Commons Attribution-ShareAlike 4.0 license. The file name is New Da Vinci Xi. It is not an FDA graphic, and it is not a news photograph. The catalog chip is HEALTH.
Plain English for the rest of the card. On Friday the FDA put out a draft playbook for companies that want to sell a surgical robot in the United States. The robot, in the agency’s words, is a software-controlled machine a qualified surgeon operates, to place and move instruments for open surgery, minimally invasive surgery, or work through a natural opening. The draft asks the maker to describe the whole system, including the console, the arms, the instruments, and the software. It asks them to measure the lag from the surgeon’s hand to the instrument and from the instrument to the picture. It asks them to test cybersecurity, including a case where the hospital network is already compromised. If the machine uses artificial intelligence, that feature needs its own testing. The notice says the draft is not final and not for use yet. Comments are due November 24, 2026, if you want them read before the agency starts the final version. The card is the patient-side cart of a da Vinci Xi.
PRIMARY here: the Food and Drug Administration’s 25 Sep 2026 Federal Register notice, Document Number 2026-19704, Docket No. FDA-2026-N-9505, 91 FR 60967 — Tier A PRIMARY, the government’s own notice. STATUS PRIMARY. The desk label on the chip is CONFIRMED because that is the catalog word for a primary page we can stand on. The draft title, the not-final and not-for-implementation sentence, the November 24, 2026 comment date, the multiple-instruments definition in the notice, Erica Takai, the non-binding language, and the filed-9-24-26 line are that notice’s. The one-or-more definition, the three subassemblies, the leader/follower sentence, the out-of-scope remote and autonomous lines, the device-description list, total system latency, the minimum of three RASDs, the cybersecurity assessment including a compromised hospital network, the AI and machine-learning examples, the Division of General Surgery Devices number, document number GUI01500081, and the meaning of should are the draft’s. AHA’s Sept. 24 dating and 02:20 PM stamp are AHA’s. The comment_end_date of 2026-11-25 is the regulations.gov record on the Federal Register API. NOT claimed: that this draft is in force, that a da Vinci Xi submission was reviewed here, that the notice’s multiple and the draft’s one or more are the same sentence, a MobiHealthNews sentence this desk did not load, a landing-page sentence this desk did not load, a guessed email for the masked address on the notice, a patient outcome, a stock tip, or investment advice. The card is the Wikimedia da Vinci Xi patient-side cart. Distinct from the already-filed nutshell-nts231-fda-ind, firefly-neurosigma-monarch, and knowtex-va-ambient-scribe. The catalog chip is HEALTH, not SIGNAL.
RELATED
On 25 Sep 2026 the Food and Drug Administration published a Federal Register notice announcing a draft guidance. The notice is Document Number 2026-19704. The docket is FDA-2026-N-9505. The agency is the Food and Drug Administration, inside the Department of Health and Human Services. The action line is “Notice of availability.” The title on the notice is “Robotically-Assisted Surgical Devices--Premarket Submissions; Draft Guidance for Industry and Food and Drug Administration Staff; Availability.” The draft’s own title, in the summary, is “Robotically-Assisted Surgical Devices--Premarket Submissions.” This desk read the notice text and the Federal Register API record for that document number. It did not sit in an operating room.
Sources
- Federal Register — RASD premarket submissions draft guidance, 25 Sep 2026
federalregister.gov
- Federal Register API — document 2026-19704
federalregister.gov
- FDA draft guidance — Robotically-Assisted Surgical Devices, Premarket Submissions
fda.gov
- FDA — guidance document landing
fda.gov
- AHA News — FDA draft guidance on RASD premarket submissions, 25 Sep 2026
aha.org
- MobiHealthNews — FDA draft guidance for robotic surgical devices, 25 Sep 2026
mobihealthnews.com
