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Validation | Assurance | C&Q

🏴󠁧󠁢󠁳󠁣󠁴󠁿 Born in Scotland 🇺🇸 Forged in Indiana

© Copyright 2026 Valkit.ai, LLC.

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Compliance Transparency

Our Position on GAMP® Categories for Digital Validation Tools

What the guidance says, what you must decide, and what Valkit.ai provides — kept rigorously separate.

Every customer receives a full validation package at no extra charge with every release of the Valkit.ai platform. Our position on GAMP® categorization is offered as context to support your independent risk assessment — not as a determination of what your organization is required to do.

Important Context

GAMP® Is Industry Best Practice, Not Regulatory Law

GAMP® is not itself a regulatory requirement. It is a globally recognized industry best practice, developed and maintained by ISPE, that provides a risk-based framework for the compliance of computerized systems in the life sciences. Regulators — including the US FDA — frequently reference GAMP® in published guidance documents and public engagements, and alignment with GAMP® is widely understood as evidence of a rigorous, scientifically sound approach to computerized system compliance.

GAMP® category definitions are tools to support risk-based decision-making. Where this page references those definitions, it is to provide context that may inform your own documented risk assessments — not to prescribe a compliance outcome. Regulated companies are solely responsible for their own classification decisions and for ensuring compliance with all applicable laws and regulations.

1

Regulatory Context

What the Guidance Says About DVTs

A distinction that is persistently missed in industry is what a DVT actually produces. When a regulated company validates a piece of equipment, a laboratory instrument, or a software system, the DVT creates and manages the digital records of that validation activity — the protocols, test scripts, executed test cases, deviation records, approvals, and final reports. These are computerized system lifecycle records: documentation of the validation process itself, not records required by predicate rules to demonstrate product quality.

The ISPE Good Practice Guide: Digital Validation, Section 1.3, and GAMP® 5 Second Edition, Appendix D9, draw a precise distinction between two categories of records a DVT may hold — and that distinction is directly relevant to any risk assessment a regulated company conducts.

Computerized System Lifecycle Records

The documentation of validating equipment, instruments, or software systems. These records do not directly support the medicinal product lifecycle, are not required by predicate rules, and are not considered GxP records per GAMP® 5 Second Edition, Appendix D9. A DVT used solely to manage such records is characterized as a GAMP® Category 1 tool for that intended use.

GxP Records Supporting the Product Lifecycle

Formal process validation plans, analytical method validation records, and process performance qualification batch data for commercial products. These are predicate rule records — analogous to batch records in an ERP. A DVT managing these records is managing GxP records, and the risk assessment must reflect that accordingly.

Customizations and Integrations

Where a regulated company configures connections to other systems, implements custom workflows, or extends the platform beyond its standard configuration, those extensions introduce additional variables that a risk assessment must account for independently. The out-of-the-box platform and any customized deployment are distinct subjects for risk assessment and should not be conflated. In a properly risk-based approach, the validation effort applied to those customizations would typically be more rigorous than that applied to the base platform.

Regulatory Expertise Behind This Position

Valkit.ai's interpretation of these guidance documents is informed by the regulatory background of its Chief Product Officer, Stephen Ferrell — a contributor to GAMP® 5 Second Edition, Chair of GAMP® Americas, member of the ISPE GAMP® Global Steering Committee, reviewer of the ISPE Good Practice Guide: Digital Validation, chapter lead on the ISPE GAMP® AI Guide, and trainer of both the US FDA and the Chinese NMPA. This does not represent the position of ISPE or any regulatory authority.

2

Your Responsibility

The Classification Decision Is Yours Alone

Whether, and to what extent, a regulated company must validate its DVT is a determination that Valkit.ai, GAMP®, or any guidance document cannot make on behalf of that company. It is a risk-based decision that each regulated entity must reach independently, through a documented assessment of their own intended use, quality system, and risk appetite.

  • Category 1 may be well-supported for core CQV/CSV useCustomers whose use of Valkit.ai is limited to managing computerized system qualification and validation documentation — IQ/OQ/PQ protocols, test execution records, traceability matrices, and lifecycle records — may find the Category 1 characterization in published guidance to be a relevant and well-supported basis for their classification decision.
  • Category 3 or 4 may reflect your use case or quality positionWhere a customer's use case extends to GxP records supporting the medicinal product lifecycle, or where internal quality procedures call for a more conservative approach, a higher classification may be the appropriate outcome of their risk assessment. Choosing Category 3 or 4 does not contradict the Category 1 characterization in published guidance — it reflects the regulated entity's own risk assessment, extended intended use, or conservative quality position.

Valkit.ai supports every classification — without exception. Whatever your organization determines through its own risk-based process, Valkit.ai will support it. We provide the guidance context, the validation documentation, and the platform support to underpin your compliance process at any classification level.

3

What Valkit.ai Provides

Full Validation Documentation. Every Release. No Extra Charge.

Valkit.ai executes and documents a complete internal validation of the platform with every software release. These deliverables are made available to all customers at no additional cost — not because any specific regulatory framework requires it for a particular use case, but because transparency and customer assurance are core to how we operate.

This internal validation does not determine the GAMP® category you should assign. It is a voluntary control we apply to give your team a well-documented foundation that supports whatever risk assessment and implementation approach your quality system requires, and to eliminate redundant validation effort on your side.

Valkit.ai Validation Package — Delivered with every platform release · Accessible to all customers · Executed within Valkit.ai

Included at no charge

VPValidation Plan
PRDProduct Requirements
FRAFunctional Risk Assessment
OQOperational Qualification
VSRValidation Summary Report
TMXTrace Matrix

Valkit.ai is not affiliated with, endorsed by, or in any way connected to ISPE (International Society for Pharmaceutical Engineering). GAMP® and ISPE® are registered trademarks of the International Society for Pharmaceutical Engineering. All rights reserved by their respective owners.

The guidance documents referenced on this page — including ISPE GAMP® 5 Second Edition, the ISPE Good Practice Guide: Digital Validation, and other ISPE publications — are available for purchase at the ISPE online store at ispe.org. Regulated companies are encouraged to obtain and consult these publications directly.

Nothing on this page constitutes legal, regulatory, or compliance advice. Each regulated company is solely responsible for its own classification and validation decisions.

Questions? [email protected]