CSV Validation Checklist — the 26-deliverable master list
The full controlled deliverable set for GAMP 5 Second Edition CSV — with applicability by GAMP category and CSA rigor selectors.
A CSV validation checklist is the controlled deliverable set a GxP computer system needs before it can be used in a regulated process. Under GAMP 5 Second Edition that runs from the Validation Master Plan through specifications, risk assessment, IQ/OQ/PQ protocols and executed records, to the Requirements Traceability Matrix and Validation Summary Report. Which items apply depends on the system's GAMP category and risk.
Planning and governance
Written before any testing starts. These define scope and who is accountable; an inspector will read them first to judge whether the rest was done deliberately.
- 1
Validation Master Plan (VMP)
Cat AllStates scope, the systems in it, the lifecycle model, roles and responsibilities, and the acceptance criteria for declaring the system validated.
- 2
Validation Plan (system-specific)
Cat AllNarrows the VMP to one system: its GAMP category, the deliverables that apply, the test strategy chosen and the written rationale for anything excluded.
- 3
System description
Cat AllDescribes what the system does, its GxP impact, interfaces, data flows and where regulated records are created or changed.
- 4
GxP assessment
Cat AllRecords the decision on whether the system is GxP-regulated at all, and why. A documented 'not GxP' is as valuable as a 'yes'.
- 5
GAMP software categorisation
Cat AllAssigns Category 1, 3, 4 or 5 with justification, because the category drives how much of this list applies.
Specification
The left arm of the V-model. Every requirement written here must be uniquely numbered, because everything downstream traces to those numbers.
- 6
User Requirement Specification (URS)
Cat AllNumbered, testable requirements expressed as what the business needs, not how the software does it. Each one must be verifiable.
- 7
Functional Specification (FS)
Cat 4, 5How the system satisfies each URS requirement. Required where the system is configured or custom.
- 8
Design Specification (DS)
Cat 5The technical design: architecture, data model, interfaces, security model. Required for custom development.
- 9
Configuration specification
Cat 4The exact configured values, workflows, roles and parameters applied to a commercial product.
- 10
Infrastructure qualification record
Cat 1Evidence that servers, network, OS and database layers beneath the application are qualified and controlled.
Risk and supplier
This is where CSA lives. The risk assessment is what justifies testing one requirement hard and another lightly — without it, a reduced test effort looks like a shortcut rather than a decision.
- 11
Functional risk assessment
Cat 3, 4, 5Scores each requirement for severity, probability and detectability, and maps each score to a test approach. The mapping must be stated, not implied.
- 12
Supplier assessment
Cat 3, 4, 5Evaluates the vendor's quality system and development practice, and states what supplier evidence you will rely on instead of re-testing.
- 13
Part 11 / Annex 11 assessment
Cat 3, 4, 5Maps each electronic-records and electronic-signature requirement to the specific configuration that satisfies it.
- 14
Data integrity assessment
Cat 3, 4, 5Identifies where regulated data is created, changed and deleted, and confirms ALCOA+ controls at each point.
- 15
Test strategy
Cat AllStates which requirements get scripted testing, which get unscripted or exploratory testing with a session record, and which rely on vendor evidence.
Test protocols
Written and approved before execution. A protocol approved after the testing was done is one of the fastest findings an inspector can write.
- 16
IQ protocol
Cat AllVerifies the system was installed as designed: correct version, approved configuration, qualified infrastructure.
- 17
OQ protocol
Cat 3, 4, 5Tests each functional requirement against defined acceptance criteria under controlled conditions.
- 18
PQ protocol
Cat 3, 4, 5Demonstrates the system performs in the real operational context, with real users, representative data volumes and actual business processes.
- 19
Test scripts with acceptance criteria
Cat 3, 4, 5Each step has an expected result defined in advance. 'Works as expected' is not an acceptance criterion.
Execution and evidence
The part that gets audited hardest. Most findings here are not about the testing — they are about the record of it.
- 20
Executed IQ / OQ / PQ records
Cat AllSigned and dated by the executor, with evidence attached. Executed in the validated environment, not in development.
- 21
Screenshot and evidence pack
Cat 3, 4, 5Legible, timestamped, attributable to the person who captured it, and traceable to the test step it supports.
- 22
Deviation log
Cat AllEvery deviation recorded, investigated, assigned an impact, and closed with a documented resolution. An accepted deviation needs a justification, not a note.
- 23
Requirements Traceability Matrix (RTM)
Cat AllLinks every URS requirement to its specification, its test case and its result, and shows coverage gaps explicitly rather than hiding them.
Closure and operation
The last two items are where validation programmes decay. Getting a system validated is a project; keeping it validated is not.
- 24
Validation Summary Report (VSR)
Cat AllConfirms all requirements were tested, all deviations closed, and the system is approved for GxP use. Signed by QA.
- 25
Change control procedure
Cat AllAssesses the regulatory impact of every change before it reaches production, and defines what triggers revalidation.
- 26
Periodic review record
Cat AllA structured review of change history, incidents, performance and current regulatory expectations, at a defined cadence. An Annex 11 obligation, and the most commonly skipped item on this list.
Not every item applies to every system. A Category 3 non-configured product will not need a Design Specification; a Category 5 bespoke system will need all 26. Document the exclusions — an item left out with a written rationale is defensible, an item simply missing is a finding.
This list reflects GAMP 5 Second Edition and FDA's 2022 Computer Software Assurance guidance. It is a working aid, not a regulatory document, and it does not replace your own quality system procedures.
Explore related resources, products and services: GxP Copilot, TraceDraft, validation services, AI transformation.
Sources
Primary documents referred to on this page, from their official publishers.
- 21 CFR Part 11: Electronic Records; Electronic Signatures · eCFR (US)
- Computer Software Assurance for Production and Quality Management System Software (final guidance, February 2026) · US FDA
- EU GMP Annex 11: Computerised Systems (current version) · European Commission
- ISPE GAMP 5 Guide, Second Edition · ISPE
- GxP data integrity guidance and definitions · UK MHRA
Common questions
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How many documents are in a CSV validation package?
Under GAMP 5 Second Edition a complete package runs to 26 controlled deliverables, from the Validation Master Plan through to the periodic review record. The number that actually applies depends on the system's GAMP category: a Category 3 non-configured product needs considerably fewer than a Category 5 bespoke system.
Which CSV deliverables are mandatory?
The items required for any GxP system are the validation plan, system description, GxP assessment, categorisation, URS, test strategy, IQ, executed records, deviation log, Requirements Traceability Matrix, Validation Summary Report, change control and periodic review. Functional and Design Specifications apply to configured and custom systems respectively.
Can I skip deliverables under CSA?
CSA changes how much testing each requirement receives, not whether the lifecycle is documented. You can reduce scripted testing where risk is low and supplier evidence is adequate, provided the functional risk assessment states the rationale. Omitting a deliverable without a written justification is a finding, not a CSA saving.
What is the difference between IQ, OQ and PQ?
IQ confirms the system was installed as designed — correct version, approved configuration, qualified infrastructure. OQ verifies each functional requirement against pre-defined acceptance criteria under controlled conditions. PQ demonstrates the system performs in the real operational context with actual users, representative data volumes and genuine business processes.
What is the most common CSV audit finding?
In our experience: test protocols approved after execution, deviations closed without a documented resolution, PQ executed in a non-production environment, and a Requirements Traceability Matrix that has not been updated since the system changed. Periodic review being overdue or never performed is close behind.
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