Since February 2, 2026, an FDA investigator can ask a medical device manufacturer for its supplier audit reports and read them. The exemption that kept those reports out of inspections for nearly three decades went away with the Quality Management System Regulation. If your last audit of a contract manufacturer was a questionnaire and a certificate on file, that file is now the exhibit.
That pressure is building everywhere suppliers touch a regulated product. EU GMP expects audits of every active substance manufacturer and distributor. ISO 9001:2026, published in September, keeps the requirement to control externally provided processes and products. Aerospace primes answer to DCMA for sub-tier quality. Across all of them, a supplier audit is the one control that a certificate cannot replace, and the one most programs run on autopilot: same suppliers, same checklist, same findings nobody closes.
The six steps below rebuild the process around risk. They cover who owns it, which suppliers to audit, how to scope the audit to the regulation that applies, what to send ahead, how to run the day on site or remotely, and how to write a report that produces corrective actions instead of a PDF. The checklist at the end covers the quality system, the compliance checks and information security in a single pass.
The Short Answer
Pick suppliers by risk tier rather than by calendar, scope each audit to the regulation that governs the material or service (ISO 13485 Clause 7.4 under the FDA QMSR, EU GMP Chapters 5 and 7, ISO 9001 Clause 8.4, AS9100), send a document request two to three weeks ahead, run the audit against objective evidence, and close every finding with an owner, a due date and verified proof. The checklist below covers quality system, compliance and information security checks with the evidence that satisfies each.
What you need before a supplier audit
Five inputs before you book the visit
A supplier audit fails before anyone gets on a plane when the program lacks the basics: a current supplier list with tiers, a written procedure, trained auditors and a regulation to audit against. Get these five in place first.
Two distinctions keep the rest of the process honest. First, a supplier quality audit is not a third-party risk assessment. The risk assessment asks whether a relationship is safe to enter and keep, across financial, cyber, compliance and resilience domains, and it is run by the third-party risk team at intake and on a monitoring cycle. The quality audit asks whether a supplier's processes produce conforming product or service, and it is run by quality against a defined standard. Mature programs feed one into the other: the risk tier decides which suppliers get audited, and the audit result changes the tier.
Second, an audit is not a certificate review. FDA said so in the QMSR preamble: certification "may not provide adequate assurances of supplier quality without further evaluation." An ISO 13485 certificate tells you a registrar found a system. Your audit tells you whether that system makes your part.
Step 1 of 6
Who owns the vendor audit process
Quality owns it, with named help
The vendor audit process belongs to the quality function, because quality owns the supplier approval decision and signs the quality agreement. Procurement, third-party risk, InfoSec and regulatory affairs each hold a piece, and the program stalls when those pieces have no names on them. A supplier quality engineer who also has to negotiate the audit date, chase the corrective action and update the scorecard is a program with one point of failure.
| Role | Owns | Does not own |
|---|---|---|
| Supplier quality (process owner) | The audit procedure, the annual schedule, auditor qualification, the report template, the approval decision | Commercial terms, the cyber assessment |
| Lead auditor | Scope, agenda, fieldwork, the report and its findings, classification of each finding | Whether the supplier stays approved |
| Procurement or category manager | The supplier relationship, the audit date, contract remedies when a finding is not closed | Findings, classifications, closure |
| Third-party risk | The risk tier, the monitoring signals that trigger an off-cycle audit, the portfolio view | The quality judgment on site |
| Regulatory affairs or compliance | Which regulation applies to each supplier type, interpretation of the criteria | Running the audit |
| Supplier's quality lead | Hosting the audit, producing evidence, owning the corrective action plan | Classifying or closing their own findings |
Give the lead auditor independence from the relationship. Under ISO 19011 the auditor should not audit a process they are responsible for, and the same logic says the engineer who qualified a supplier last year should not be the only person who audits it this year. Rotate leads on critical suppliers at least every other cycle.
Step 2 of 6
Pick suppliers to audit by risk tier
Frequency follows the tier
Most audit schedules are built the way they were inherited: every approved supplier every three years, critical ones annually, and whoever has capacity in Q4 picks up the backlog. That schedule audits the calendar. The regulations want you to audit the risk. ISO 13485 Clause 7.4, which the QMSR now applies to US device manufacturers, ties the extent of supplier evaluation to the effect of the purchased product on the quality of the finished device and to the risk of that device. EU GMP Chapter 5 puts it as supervision "proportionate to the risks posed by the individual materials, taking account of their source, manufacturing process, supply chain complexity and the final use."
Tier on four inputs, scored at approval and updated by monitoring: the effect of the supplier's product or service on your finished product (a sterilization contractor and an API manufacturer sit at the top, an office supplies vendor at the bottom), the supplier's own process complexity and change history, supply chain complexity (brokers, distributors and sub-tiers between you and the maker), and performance history: nonconformances, late deliveries, complaints traced to the supplier, prior audit findings. The role of a supplier audit in risk management is to verify the tier you assigned, then feed the result back into it.
| Tier | Who sits here | Audit frequency & method |
|---|---|---|
| Tier 1 Critical | Contract manufacturers, CMOs and CROs, API and critical component makers, sterilization and testing labs, sole-source suppliers of flight-critical or implantable parts | On-site audit before approval and at least every 12 to 24 months, plus a for-cause audit on any major nonconformance, recall signal or ownership change |
| Tier 2 High | Suppliers of controlled materials, custom components, calibration services, software that touches product or records | On-site or remote audit every 24 to 36 months, desk review of certificates and performance data in between |
| Tier 3 Medium | Catalog components to a specification, packaging, logistics, non-product software | Remote or desk audit on a 36-month cycle, triggered on-site audit only on a signal |
| Tier 4 Low | Commodity and indirect suppliers with no effect on product | No audit. Certificate check, performance monitoring and trend review |
The ranges are a working starting point for a mature program, not a rule, and your procedure should say what moves a supplier between tiers. Certa's platform scores every third party across seven risk domains and schedules periodic assessment tuned to each vendor's risk tier. Quantcast used tiering of that kind to cut vendor onboarding to a 7-day cycle for high-risk vendors and 5 days for low-risk ones, which is the same principle applied to audits: the effort goes where the exposure is.
Step 3 of 6
Set the audit scope & criteria
One audit, one standard, written down
Scope is the sentence at the top of the audit plan that says which processes, sites, products and time period the audit covers, and criteria is the list of documents you are auditing against. Write both before you send the notification. An audit with no criteria produces opinions. An audit with the wrong criteria produces findings the supplier will reject on day one.
Criteria depend on what the supplier makes for you. For a medical device vendor audit of a contract manufacturer or critical component supplier, the criteria are ISO 13485:2016 and the FDA quality management system regulation, which amended 21 CFR Part 820 to incorporate ISO 13485:2016 by reference (§ 820.7 and § 820.10) and took effect on February 2, 2026. Scope the audit to the ISO 13485 clauses the supplier's work touches: 7.4 for their own purchasing, 7.5 for production and process validation, 8.2 for monitoring, 8.3 for nonconforming product, 8.5 for corrective and preventive action. If the supplier makes a finished device for you, the QMSR applies to them directly and the audit should test it.
A pharma supplier audit of an API or excipient manufacturer uses EU GMP Chapter 5 (sections 5.27 to 5.29 on supplier qualification), ICH Q7 for active substances, and 21 CFR Parts 210 and 211 for product bound for the US. One criterion worth auditing explicitly: 21 CFR 211.84(d)(2) lets you accept a supplier's certificate of analysis in place of full testing only if you run at least one specific identity test and establish "the reliability of the supplier's analyses through appropriate validation of the supplier's test results at appropriate intervals." If you rely on their COA, the audit should examine the lab that produced it. For a CMO or contract lab, add EU GMP Chapter 7: the contract giver assesses "the legality, suitability and the competence" of the contract acceptor before outsourcing (7.5) and reviews the acceptor's records and results on an ongoing basis (7.8).
Aerospace and defense suppliers are audited against AS9100 Rev D (2016), which carries the ISO 9001 text plus the aerospace additions on configuration management, product safety, counterfeit parts prevention and control of externally provided processes. IAQG's next revision, renumbered IA9100, was still in development when ISO 9001:2026 published, so confirm which edition your prime and certification body expect before you set criteria. For any supplier certified to ISO 9001, the current standard is ISO 9001:2026 (Edition 6, September 2026), which withdrew ISO 9001:2015. Ask the supplier where they are in the transition and audit to the edition on their certificate.
| Supplier type | Primary criteria | Add to scope |
|---|---|---|
| Device contract manufacturer or critical component | ISO 13485:2016 as incorporated by the FDA QMSR (21 CFR Part 820), the quality agreement | Process validation records, complaint and nonconformance trending, their own supplier controls (Clause 7.4) |
| API, excipient or starting material maker | EU GMP Chapter 5 (5.27 to 5.29), ICH Q7, 21 CFR 211.84 | Supply chain traceability to the starting material, COA reliability, cross-contamination controls |
| CMO, CRO or contract lab | EU GMP Chapter 7, the quality or technical agreement, GCP for clinical work | Subcontracting (7.11), change control (7.12), record retention and access (7.16) |
| Aerospace machining, special process or distributor | AS9100 Rev D, the prime's flow-down requirements, Nadcap for special processes | Counterfeit parts prevention, sub-tier flow-down, OASIS certification record, FOD control |
| Any ISO 9001 supplier | ISO 9001:2026 (or 2015 until their transition closes), Clause 8.4 | Type and extent of control over their own external providers, documented information for release |
In life sciences the scope also has to cover the regulations beyond quality that the agencies attach to third parties: ABAC and FCPA exposure for distributors and sales intermediaries, GCP for CROs, HIPAA where a supplier handles protected health information. Certa's life sciences supplier compliance page lists the frameworks a program in this industry is expected to cover, and the audit plan should name the ones that apply to the supplier in front of you, so the auditor is not improvising compliance questions between quality sections.
Step 4 of 6
Send a pre-audit questionnaire & document request
Read the system before you see it
Send the notification, the agenda and a document request 15 to 20 working days before the audit. The documents you read in advance decide what you sample on site. An auditor who arrives without having read the supplier's quality manual, procedure index and last two management reviews spends the first morning getting oriented and the afternoon rushing.
Keep the pre-audit questionnaire short. Its job is to confirm scope and surface changes since the last audit, not to pre-run the audit by email. Ten to twenty questions is enough: current certifications and their scope statements, changes to sites, processes, equipment or key personnel, open regulatory actions or customer audits in the last 12 months, sub-tier suppliers used for your product, and any outsourced processes.
The document request is where a supplier audit template earns its keep. Standardize the list by supplier type so every auditor asks for the same core set, then let the lead auditor add product-specific items. A working core set:
- Quality manual, procedure index and organization chart with quality's reporting line
- Current certificates with scope statements, plus the last external audit report and any open findings
- Last two management review records and the internal audit schedule with results
- Nonconformance, CAPA and complaint logs for the last 12 to 24 months, with trend data
- Change control log, and the change records that touched your product
- Process validation summaries and the calibration status list for equipment used on your product
- Training matrix for the roles on your product line
- Approved supplier list for the sub-tier suppliers and outsourced processes behind your product
- Record of your product's last five lots or deliveries: batch records, test results, release
Ask for records, not statements about records. A supplier that answers the CAPA request with a sentence about having a CAPA procedure has told you what to sample first.
Step 5 of 6
Run the on-site or remote audit
Evidence, traced lot by lot
The vendor audit on the day has one method: trace. Pick a lot, batch or delivery of your product and follow it backward through the supplier's system. Purchase order to incoming inspection of their materials, to the batch record, to the equipment and its calibration, to the operator and their training record, to in-process and final test, to release and shipment. Then pick a nonconformance and follow it forward to the CAPA, the effectiveness check and the closed record. Every finding you write should point at an objective record, a dated observation or a measured result, not at an interview answer.
- Opening meeting, 20 minutes: confirm scope, criteria, agenda, confidentiality, how findings will be classified and when the supplier will see the draft.
- Facility tour with the process owners, in process order. Note housekeeping, segregation of nonconforming material, label control and equipment status tags as you go.
- Trace sampling: two to three lots of your product end to end, plus one nonconformance and one change record end to end.
- Clause or section coverage: work through the remaining criteria with the documents requested in advance, sampling records against each.
- Daily wrap-up on multi-day audits, so nothing in the final meeting is a surprise.
- Closing meeting: read each finding with its evidence and classification, agree the corrective action timeline, state what happens to approval status.
Remote audits became normal in 2020 and are a legitimate method when the evidence is documentary and the risk supports it. They are the wrong method when the finding you need lives on the shop floor: cleanroom behavior, segregation, equipment condition, whether the procedure on the wall matches the procedure in the binder. FDA's QMSR preamble allows that where audits are not practical, supplier capability can be assessed through historical data, monitoring and trending, inspection and testing, among other means, which is a floor for the lowest tiers, not a substitute at the top. The Interagency Guidance tells banks to document the limitation when a third party will not allow on-site visits and to mitigate the risk another way. Apply the same discipline: when you go remote, write down why.
| Choose | When | Watch for |
|---|---|---|
| On-site | Tier 1 suppliers, initial approval of any supplier with product-affecting processes, for-cause audits, special processes (sterilization, heat treat, plating), any site with prior major findings | Agenda drift. Keep the trace sampling on the plan even when the tour runs long |
| Remote (live video plus document review) | Tier 2 surveillance audits with a clean history, document-heavy scopes (design, software, labs with electronic records), sites where travel is restricted | Curated evidence. Ask for live screen share of the QMS and pick the records yourself |
| Desk review | Tier 3 suppliers, certificate and performance verification between audits | Treating it as an audit in the report. Call it what it is |
| Hybrid | Tier 1 surveillance where a short on-site day covers the floor and remote sessions cover records | Splitting the team so nobody sees the whole picture |
Step 6 of 6
Write the supplier audit report & corrective actions
A report that closes
EU GMP sets the standard for what a supplier audit report should do: it "should fully reflect what was done and seen on the audit with any deficiencies clearly identified," and "any required corrective and preventive actions should be implemented." Those two sentences describe most of the audit reports that fail. It says the audit happened and lists findings. It does not say what was sampled, which records were seen, or what happened next.
Issue the draft within 10 working days and the final within 20. Give the report a fixed structure so an inspector, a second auditor or a procurement lead can read any of them the same way:
- Scope, criteria, sites, dates, auditors and supplier attendees.
- Method: which lots, records and processes were traced, how many records were sampled per area, and what was not covered and why.
- Findings, each with a classification, the requirement it fails, the objective evidence (record number, date, observation) and the auditor's assessment of effect on your product.
- Overall conclusion and recommended approval status: approved, approved with conditions, suspended, or disqualified.
- Corrective action requirements: what the supplier must submit, by when, and what evidence will close each finding.
Corrective action is where the audit either changes something or does not. Require a root cause, a correction and a corrective action for every major, with an owner and a due date, and verify closure with evidence rather than a statement that the action is complete. For a major that affects product already delivered, the report triggers your own nonconformance and, where it applies, a review of released product. Under ISO 13485 Clause 7.4 the supplier's performance in closing findings becomes part of the record you re-evaluate them on, and under the QMSR that record is now within an FDA investigator's reach: FDA's April 1, 2026 town hall on the new inspection program said supplier audit processes are expected to be reviewed in baseline surveillance and premarket approval inspections.
Feed the result into the scorecard. An audit outcome that lives in a PDF and a scorecard that lives in a spreadsheet will disagree within a quarter. Certa's vendor scorecards guide covers the quality, delivery, compliance and risk categories a scorecard should carry, and the audit result belongs in the quality and compliance rows with a date. Certa's lifecycle runs a Remediation stage that resolves findings with assigned tasks and tracked evidence, and its Contracts Agent extracts the obligations, SLAs and key dates from the quality agreement so the audit clause and the corrective action commitments sit on the supplier record rather than in a filed contract. Every disposition on the platform is captured with documented rationale, citations and timestamps, immutable and exportable on demand, which is the shape an audit trail needs to be in when the inspector asks for it.
Use this supplier audit checklist
Quality, compliance & security in one pass
This supplier audit checklist is organized the way an audit day runs: the quality system first, then the compliance and ethics checks that quality auditors usually skip, then the information security and data handling checks that InfoSec would ask if they were in the room. Each row names the area, what to check and the evidence that satisfies it. Use it as a vendor audit checklist for any supplier type, and cut the rows that do not match the scope you set in Step 3.
Quality system & ISO 9001 supplier audit checklist items
These rows work as an ISO 9001 supplier audit checklist and map to the equivalent ISO 13485 and AS9100 clauses, with the device and pharma additions marked. Its evidence column is the record you should be holding, not the statement you should be hearing.
| Area | What to check | Evidence |
|---|---|---|
| Quality management system | Current certificate scope covers your product and the site audited. Quality manual and procedures reflect the current edition of the standard | Certificate with scope statement, procedure index with revision dates, last registrar audit report |
| Management review & internal audit | Reviews held at the planned interval with inputs on your product's performance, internal audits cover every process on a cycle, findings closed | Management review minutes, internal audit schedule and reports, closure records |
| Document & record control | Current revisions at the point of use, obsolete documents removed, records retained for the period your contract or regulation requires | Spot check of three procedures on the floor against the master list, retention schedule |
| Control of external providers | Their own sub-tier suppliers are evaluated, approved and monitored with extent of control tied to risk (ISO 9001 8.4, ISO 13485 7.4) | Approved supplier list, evaluation records for the suppliers behind your product, incoming inspection records |
| Production & process control | Work instructions match the current product specification, in-process checks performed and recorded, environment controlled where it affects product | Batch or traveler records for two to three lots of your product, environmental monitoring where applicable |
| Process validation | Processes whose output cannot be fully verified are validated, revalidated on change, operated inside validated parameters (ISO 13485 7.5.6) | Validation protocols and reports, change records that triggered revalidation |
| Equipment, calibration & maintenance | Measuring equipment calibrated to a traceable standard, status visible, out-of-tolerance events investigated for product impact | Calibration list with due dates, calibration certificates, out-of-tolerance investigations |
| Identification & traceability | Material and product identified through production, traceability to the level your regulation requires (lot, serial, UDI for devices) | Trace of one delivery backward to raw material lots |
| Nonconforming product | Segregated, dispositioned by authorized people, concessions documented and, where required, approved by you | Nonconformance log, segregation area, concession records tied to your product |
| Corrective & preventive action | Root cause recorded, actions implemented, effectiveness verified, trends reviewed | CAPA log, two CAPAs traced end to end, trend report |
| Change control | Changes to process, material, equipment, site or sub-tier supplier assessed and, where the quality agreement requires it, notified to you before implementation | Change log, notification records sent to customers |
| Training & competence | People on your product line trained to the current procedure revision, competence demonstrated for special processes | Training matrix, records for the operators on the lots traced |
| Complaints & field actions | Complaints investigated, reportable events assessed, your product's complaints visible | Complaint log, investigation records, regulatory reporting decisions |
| Pharma addition: COA reliability | Supplier's test methods and lab support the certificate you rely on, identity testing and periodic full-analysis comparison in place (21 CFR 211.84(d)(2), EU GMP 5.35) | Lab records, method validation, your own comparison results |
| Aerospace addition: counterfeit parts & flow-down | Counterfeit parts prevention process in place, prime's requirements flowed to sub-tiers, FOD control on the floor | Counterfeit prevention procedure, purchase orders to sub-tiers showing flow-down, FOD audit records |
Compliance, ethics & sanctions checks
A supplier can run a clean quality system and still be a compliance exposure. These checks take an hour and keep the audit from certifying a supplier your compliance team would have blocked.
| Area | What to check | Evidence |
|---|---|---|
| Sanctions & denied party screening | The supplier, its owners and its own key suppliers are screened against current sanctions and denied party lists, and the supplier screens its customers where export controls apply | Screening records with dates, the list sources used, your own screening result for the supplier and its UBOs |
| Anti-bribery & corruption | Written ABAC policy, training for people who deal with officials, gifts and hospitality register, due diligence on agents and intermediaries | Policy, training records, register, intermediary due diligence files |
| Export controls & trade compliance | Classification of your product and materials, ITAR or EAR registration where it applies, licenses on file, country of origin determinations | Registration, license records, classification records, customs documentation |
| Forced labor & responsible sourcing | Supply chain mapping for materials in scope of UFLPA or similar statutes, supplier code of conduct flowed down, audit or assessment of high-risk sub-tiers | Mapping records, signed code of conduct, sub-tier assessment reports |
| Conflict minerals & material compliance | Where in scope, Dodd-Frank 1502 reporting, REACH and RoHS declarations current for the materials supplied | Conflict minerals reporting template, declarations with dates |
| Licenses, permits & regulatory status | Manufacturing authorizations, FDA registration and listing, environmental and safety permits current for the site | Authorization or registration records, inspection history, open regulatory actions |
| Subcontracting & outsourcing | Nothing in your scope is subcontracted without your agreement (EU GMP 7.11), subcontractors held to the same requirements | Subcontract list, quality agreements with subcontractors, your approvals |
| Business continuity | Documented plan for the processes that make your product, tested within the last 12 months, single points of failure identified | Plan, test record, critical equipment and material list |
Information security & data handling checks
Suppliers hold your drawings, specifications, batch records and often your customer data. For a defense supplier handling controlled unclassified information, these rows are a contract requirement under DFARS and CMMC rather than a nice-to-have.
| Area | What to check | Evidence |
|---|---|---|
| Security program & attestation | A named security owner, a framework the program follows, current independent attestation where the data warrants it | SOC 2 Type II report or ISO 27001 certificate with scope, NIST SP 800-171 assessment or CMMC status for CUI |
| Access control | Access to your technical data limited to the people who need it, removed at exit, multi-factor authentication on remote and administrative access | Access list for your project folders, joiner and leaver records, MFA configuration |
| Protection of your technical data | Drawings, specifications and records stored and transmitted with encryption, marked and handled per your agreement, not shared with sub-tiers without approval | Data handling procedure, storage locations, sub-tier NDAs and data sharing approvals |
| Electronic records & data integrity | Systems that create GMP or quality records have audit trails, controlled access, backup and validated software (21 CFR Part 11 where it applies) | Audit trail review, system validation records, backup and restore test |
| Incident response & notification | Documented incident process, a contractual notification window to you, incidents in the last 24 months disclosed | Incident response procedure, notification clause, incident log |
| Vulnerability & patch management | Production and business systems patched on a schedule, operational technology on the floor inventoried and segmented | Patch records, OT asset inventory, network segmentation diagram |
| Backup & recovery | Quality records and production systems backed up, recovery tested, recovery objectives match the continuity plan | Backup schedule, last restore test, recovery time and point objectives |
Score the checklist, do not just tick it. Give each row a result of conforming, minor, major or not applicable, and write the evidence reference in the row. That scored checklist becomes the method section of the report, and the next auditor can see exactly what was sampled last time and sample something else.
Common supplier quality audit mistakes
Where audits lose their value
These show up in the first review of almost any supplier quality audit program that has run for a few years without being audited itself. Each has a fix that costs less than the next inspection.
- Auditing on a calendar instead of a tier. Every supplier every three years treats the sterilizer and the label printer the same. Fix: the tier table in Step 2, with a trigger list for off-cycle audits.
- Accepting the certificate as the audit. FDA's own words: certification may not provide adequate assurance without further evaluation. Fix: the certificate confirms scope, the audit samples records.
- No criteria in the plan. Findings written against the auditor's preference get rejected and the report loses authority. Fix: name the standard, edition and clauses in the plan and in every finding.
- Interviews instead of traces. A supplier can describe a perfect CAPA process for an hour. Fix: two lots and one nonconformance traced end to end on every audit.
- Findings that never close. A report goes out, the supplier promises action, and nobody checks. Fix: owner, due date, closure evidence and an effectiveness check date in the report, tracked in the system that holds the supplier record.
- Quality and compliance in separate audits, or compliance in none. The quality auditor never asks about sanctions screening and the compliance team never visits the plant. Fix: the compliance rows of the checklist, run by the lead auditor with compliance input on the criteria.
- Reports nobody else can read. Every auditor writes a different report and the method is in their head. Fix: the fixed report structure in Step 6, with the scored checklist as the method section. Certa's audit transparency steps cover the same ground: standardized procedures, documented rationale, and findings that are communicated and acted on, not filed.
- Treating the supplier audit report as internal. Under the QMSR it is not exempt from FDA inspection anymore, and under MDSAP it never was. Fix: write every report as if an investigator will read it, because one may.
Sources
- FDA, Quality Management System Regulation (QMSR), effective February 2, 2026
- eCFR, 21 CFR Part 820, Quality Management System Regulation (§§ 820.7, 820.10, 820.35)
- Federal Register, Medical Devices; Quality Management System Regulation, final rule, 89 FR 7523 (February 2, 2024)
- FDA, CDRH Town Hall transcript: FDA's QMSR, Medical Device Risk-Based Inspections (April 1, 2026)
- eCFR, 21 CFR 211.84, Testing and approval or rejection of components, drug product containers, and closures
- European Commission, EudraLex Volume 4, EU GMP Guide Chapter 5: Production (in operation 1 March 2015)
- European Commission, EudraLex Volume 4, EU GMP Guide Chapter 7: Outsourced Activities (revision 1)
- ISO, ISO 13485:2016 Medical devices, Quality management systems, Requirements for regulatory purposes
- ISO, ISO 9001:2026 Quality management systems, Requirements (Edition 6, September 2026)
- ISO, ISO 19011:2026 Guidelines for auditing management systems (Edition 4, May 2026)
- NASA Office of Safety and Mission Assurance, Status of the Development of IA9100 (April 17, 2024)
- IAQG, Online Aerospace Supplier Information System (OASIS)
- Board of Governors of the Federal Reserve System, FDIC and OCC, Interagency Guidance on Third-Party Relationships: Risk Management (June 2023)
Supplier audit FAQ
Short answers to the questions that come up every time a program rebuilds its supplier audit procedure.
How Often Should You Audit Suppliers?
As often as the supplier's risk tier and history justify, not on a fixed calendar for everyone. A working range is an on-site audit of critical suppliers every 12 to 24 months, high-risk suppliers every 24 to 36 months, medium-risk suppliers by remote or desk review on a 36-month cycle, and no routine audit for low-risk suppliers. EU GMP Chapter 5 puts it as further audits "at intervals defined by the quality risk management process," and any major nonconformance, recall signal, site move or ownership change should trigger an audit regardless of where the supplier sits in the cycle.
What Is the Difference Between a Supplier Audit & a Supplier Assessment?
A supplier assessment is a judgment formed from documents and data: questionnaires, certificates, performance history, financial and cyber ratings, and it can be done without visiting the supplier. A supplier audit is a systematic, evidence-based examination against defined criteria, run by qualified auditors who sample records and observe processes, on site or remotely. Assessments decide the tier and whether an audit is needed. Audits verify that the supplier's system does what the assessment assumed, and under ISO 13485 Clause 7.4 and EU GMP 5.29 the audit is the control a certificate cannot replace for high-risk suppliers.
How Do Pharma Supplier Audits Differ?
Pharma supplier audits are governed by GMP rather than a generic quality standard, so the criteria, the evidence and the obligations are specific. EU GMP Chapter 5 requires audits at the manufacturers and distributors of active substances, with reports that fully reflect what was done and seen, and Chapter 7 makes the contract giver responsible for assessing a contract acceptor's legality, suitability and competence before outsourcing. In the US, 21 CFR 211.84(d)(2) conditions any reliance on a supplier's certificate of analysis on identity testing and periodic validation of the supplier's results, which puts the supplier's laboratory inside the audit scope. Expect more emphasis on supply chain traceability, cross-contamination, data integrity of batch and lab records, and the quality agreement.
Can Supplier Audit Software Replace On-Site Visits?
No, and it should not try to. Supplier audit software replaces the spreadsheet, the inbox and the filed PDF: it holds the risk tier, schedules audits by tier, issues the document request, stores the evidence and tracks corrective actions to closure with an audit trail. That makes remote and desk audits defensible for lower tiers and keeps on-site findings from getting lost. The decision to go on site still follows the risk: critical suppliers, special processes, initial approvals and for-cause audits need an auditor on the floor, and the regulations expect you to document why when you choose otherwise.
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