🗒️ Compliance Guide

21 CFR Part 11
Compliance Guide

What 21 CFR Part 11 actually requires — and how AILS enforces each control at the architecture layer, not the policy layer.

21 CFR Part 11 Electronic Records e-Signatures FDA Audit Trail

What Part 11 Actually Requires

Policy vs. architecture — the difference that matters

Most LIMS vendors handle 21 CFR Part 11 with written policies — they tell you what you're supposed to do and leave the enforcement to your team. AILS enforces Part 11 at the code level. The controls aren't optional, configurable, or bypassable by a user with the right role. Here's what that means, clause by clause.

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The FDA's core question during an inspection
Investigators don't just ask "do you have a policy for this?" — they ask for live system evidence. They want to see audit logs that can't be edited, re-authentication that actually fires before a signature, and record exports that include an integrity hash. AILS is built to answer every one of those requests with a live demonstration, not a binder.
§11.10(a) Validation
Systems used to create, modify, maintain, archive, retrieve, or transmit electronic records must be validated to ensure accuracy, reliability, consistent intended performance, and the ability to discern invalid or altered records.
AILS AILS ships with a Vendor Validation Package (VVP) — a pre-built IQ/OQ/PQ bundle including a Requirements Traceability Matrix, 16 executed OQ test cases with pass/fail evidence, GAMP 5 Category 4 classification, and a §11.100(c) e-signature declaration. Generated on demand from your Compliance module, always reflecting the current system version.
§11.10(b) Accurate and Complete Copies
The ability to generate accurate and complete copies of records in both human readable and electronic form suitable for inspection, review, and copying by the agency.
AILS Every COA, CAPA, deviation, SOP, audit log, and management review is exportable as PDF with embedded SHA-256 integrity hash. The hash can be independently verified via the public certificate verification endpoint — confirming the record has not been altered since issuance.
§11.10(c) Record Protection & Retention
Protection of records to enable their accurate and ready retrieval throughout the records retention period.
AILS Every record is scoped to its tenant on every query, checked by an isolation test suite on every release. Bring-your-own database and EU hosting give a tenant a dedicated database. Default retention is 7 years, configurable to match your accreditation requirements. Records are never deleted during the retention window — only archived. Full export is available at any time in standard formats.
§11.10(d) Limiting System Access to Authorized Users
Limiting system access to authorized individuals.
AILS Role-based access control with four tiers — Admin, Manager, Technician, Read-Only — enforced at the API level on every request. Module-level licensing gates access to COC, COA, QMS, and Equipment independently. Training currency enforcement: expired training blocks the five signing and issuing actions (COA issue, COC acceptance, SOP signoff, test-report issue, Report Builder issue), regardless of role.
§11.10(e) Audit Trail
Use of secure, computer-generated, time-stamped audit trails to independently record the date and time of operator entries and actions that create, modify, or delete electronic records. Record changes shall not obscure previously recorded information.
AILS 5-year immutable audit trail on every action across the platform. Each entry captures: user ID, full name, IP address, timestamp, action type, affected record ID, and the previous and new values for any field changed. The audit log is append-only — no record can be modified or deleted. Suspicious activity detection flags critical events. Exportable as PDF for inspections.
§11.10(f) Operational System Checks
Use of operational system checks to enforce permitted sequencing of steps and events, as appropriate.
AILS Workflow sequencing is enforced at the system level. A COA cannot be issued until all required results are entered. A CAPA cannot be closed until root cause and corrective action are documented. A batch release cannot be initiated until the batch record is complete. These gates are not warnings — they are hard stops enforced by the API.
§11.10(g) Authority Checks / Re-Authentication
Use of authority checks to ensure that only authorized individuals can use the system, electronically sign a record, access the operation or computer system input or output device, alter a record, or perform the operation at hand.
AILS Re-authentication is required before every critical signing event — COA issuance, SOP approval, CAPA closure, batch release, COC acceptance. Active session state alone is not sufficient. The user must re-enter their credentials at the point of signature. This fires regardless of how recently they logged in, closing the session-hijacking gap that policy-only systems miss.
§11.10(h) Device Checks
Use of device checks, as appropriate, to determine, as warranted, the validity of the source of data input or operational instruction.
AILS Token-based authentication with short-lived access tokens and rotating refresh tokens. Account lockout after 5 failed attempts with a 15-minute lock and a critical audit event. Generic error responses prevent account enumeration. All authentication events — success and failure — are logged with IP address and device metadata.
§11.10(i) Personnel Qualifications
Determination that persons who develop, maintain, or use electronic record/electronic signature systems have the education, training, and experience to perform their assigned tasks.
AILS Training records are maintained per user, linked to specific roles and test methods. The system enforces training currency — a user with expired training is blocked from the five signing and issuing actions: issuing a COA, accepting a COC, signing off an SOP, issuing a test report and issuing a Report Builder report. Training records are included in audit exports and are accessible for inspection without manual compilation.
§11.10(j) Written Policies — Accountability
The establishment of, and adherence to, written policies that hold individuals accountable and responsible for actions initiated under their electronic signatures, in order to deter record and signature falsification.
AILS Three §11.10(k) policy documents are available from the Compliance module: Incident Response Policy, Periodic System Validation Review Schedule, and Intended Use Statement. Each is version-controlled and signed electronically on acceptance, with the signing record stored in the audit trail.
§11.100(a) Each Electronic Signature Is Unique to One Individual
Each electronic signature shall be unique to one individual and shall not be reused by, or reassigned to, anyone else.
AILS Every user account has a unique identifier that cannot be shared, transferred, or reassigned. Signing credentials are bound to the individual user account — not a role or team account. Shared login accounts are architecturally prevented; each user must have their own credentials to access the platform.
§11.100(c) E-Signature Declaration
Before an organization establishes, assigns, certifies, or otherwise sanctions an individual's electronic signature, or any element of such electronic signature, the organization shall certify to the agency that the electronic signatures in their systems are the legally binding equivalent of traditional handwritten signatures.
AILS The §11.100(c) vendor declaration letter is included in the Vendor Validation Package — certifying that all electronic signatures in AILS are intended to be the legally binding equivalent of handwritten signatures. This letter is generated on demand, always reflecting the current platform version, and is ready for FDA submission without additional preparation.
§11.200(a) Electronic Signature Components & Controls
Electronic signatures not based upon biometrics shall employ at least two distinct identification components such as an identification code and password.
AILS All signatures require two-factor authentication: the user's password plus a TOTP (time-based one-time password) from an authenticator app. 2FA is enforced on all signing events for regulated workflows. Signed records capture the authentication method used alongside the signature timestamp, user identity, and record state.

The Vendor Validation Package

Your §11.10(a) evidence — already built

The VVP is not a static PDF written three years ago. It is generated from live system state — current test results, current version, current executed OQ evidence — every time you download it.

🗂️ What's in the Vendor Validation Package

Drop it straight into your Computer System Validation binder

Available on demand from the Compliance module. Every document reflects the current system version with live test evidence. No preparation required before handing it to your auditor or FDA investigator.

Requirements Traceability Matrix (RTM)
16 Executed OQ Test Cases
IQ / OQ / PQ Templates
§11.100(c) E-Signature Declaration
GAMP 5 Category 4 Classification
System Description & Intended Use
1232Automated Tests
100/100Health Score
5yrAudit Retention
GAMP 5Category 4

What You Get

Architecture-level enforcement — not configuration

Every Part 11 control above is enforced by the system. No administrator toggle. No "enable compliance mode." No checklist for your team to follow and hope they remember.

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Re-Auth at Every Critical Signature

COA issuance, CAPA closure, batch release, SOP sign-off — every consequential action requires credential re-entry. Session state alone is never sufficient to sign.

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Immutable Audit Trail

Append-only, tamper-evident log of every action. Previous values are preserved — never overwritten. 5-year retention, PDF export, suspicious activity detection built in.

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2FA on All Signing Events

TOTP-based two-factor authentication enforced on all regulated workflows. The §11.200(a) two-component requirement is satisfied at the system level on every signature.

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SHA-256 Record Integrity

Every issued COA and signed record carries a SHA-256 hash. Tamper detection is verifiable independently via the public certificate endpoint — no AILS account required.

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VVP Generated On Demand

Complete IQ/OQ/PQ package downloadable from your Compliance module. Always current. Always based on live test evidence. Ready for your CSV binder or FDA inspection.

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Training-Gated Signing

Expired training blocks the five signing and issuing actions at the API — not by a manager remembering to check. Those actions are not available to a user whose training has lapsed.


Ready for an FDA inspection on Part 11?

Book a 30-minute demo. We'll pull up the live audit trail, fire a re-authentication event, and generate the VVP — all in real time.

Also see: Computer System Validation (IQ/OQ/PQ) · ISO 17025 Readiness Checklist · GMP Batch Release Workflow · Pricing