Validation and
Agile Methods
Across all sectors of the economy, IT solutions are diversifying and evolving rapidly. Pharmaceutical and medical device manufacturers also seek speed and flexibility. When developing or configuring their systems, companies can choose between the traditional model known as the V-cycle or the Agile approach. Once operational, the system must function reliably and reproducibly in compliance with regulatory requirements, regardless of its development life cycle. How can a system developed under an Agile methodology be validated and maintained in a validated state?
Regulatory Compliance: Agility and the V-Cycle
The regulations governing medical devices and pharmaceutical products apply regardless of the software development life cycle.
The Agile approach
Agile methods are iterative, meaning they involve successive development cycles. Each iteration is based on key elements such as user requirements and acceptance criteria, which serve as the foundation for starting the development cycle. At the end of each iteration, a version—or increment in Agile terminology—is produced and should be usable by end users. The principle is to deliver reliable versions of the system even if not all features are finalized.
Unlike the V-cycle model, Agile allows development to begin without drafting detailed functional specifications upfront, as users and Quality Assurance are involved from the start and continuously validate the functional response.
The Agile approach is well suited when system requirements cannot all be defined precisely at the start of the project. Historically, web projects were among the first to adopt it—for example, adding a GxP chatbot. The key idea is that users can access new functionalities as updates are released to production and can modify requirements throughout the system’s lifecycle.
The term Agile methods covers multiple frameworks aligned with the 2001 Agile Manifesto, such as Scrum, eXtreme Programming (XP), Feature Driven Development (FDD), Rapid Application Development (RAD), and Behavior Driven Development (BDD).
Agile development originally applied mainly to software development phases. Depending on the method, some start at the pre-project and feasibility phases, while others focus more on project execution. The latter are mainly used in regulated environments (e.g. Scrum).
The V-Cycle
The V-cycle model is a variant of the Waterfall software development model. It follows a sequential process in which each step must be completed before the next can begin. The descending branch represents design phases, while the ascending branch represents testing. Each design phase corresponds to a verification phase.
This method requires a precise definition of requirements from the beginning. It is best suited to systems with limited changes during development. The initial schedule and functional scope are not expected to evolve. The traceability between requirements and tests ensures documented quality control at each stage.
What do the regulations say?
In the pharmaceutical sector, there is no incompatibility between validation principles and the Agile approach. The 2022 second edition of the GAMP® 5 Guide supports this view, setting out key requirements without prescribing a specific development model. It describes five phases: planning, specification, configuration (or coding), verification, and reporting.
Risk management must be integrated throughout all stages, requiring dynamic risk assessment. Similarly, regulations on medical devices (Regulations (EU) 2017/745 and (EU) 2017/746) do not impose any particular software design or development sequence.
Note that the chosen development method has no impact on the content of the required documented evidence, which must comply with standard expectations.
The Agile approach can therefore be implemented within a GxP environment as long as it integrates regulatory requirements related to software documentation and the quality management system. In particular, maintaining control of requirement traceability throughout development is essential.
When and how to validate using the agile approach?
In Agile development, the GAMP 5 phases are conducted within each iteration, resulting in a system increment corresponding to a usable version of the application. During each cycle, this increment is validated to ensure it meets user requirements and design specifications.
Validation must demonstrate lifecycle control and requires the same deliverables as GxP systems developed under the V-cycle. However, validation organization differs under Agile: the project team is multidisciplinary—typically including a developer, user, and validator—all working concurrently rather than sequentially. Additionally, specific tools are essential for successful Agile implementation.
In regulated sectors, projects are often hybrid: a partially iterative Agile phase (including UATs, installation and functional verifications, and data migration) followed by a final validation phase before production release, involving performance qualification.

For instance, an embedded software system may be developed using Agile but validated according to a V-cycle model before final delivery.
Organization
In Agile practice, validation is an integral part of development, not an afterthought. Agile is fundamentally a mindset emphasizing collaboration, transparency, and communication—all of which apply to validation. The validation lead must be part of the team and trained in Agile principles and practices.
A special case arises when a company uses Software as a Service (SaaS). The provider may update the software frequently using Agile development. The client is notified of each version update and must adapt its validation strategy based on the associated risk to avoid full revalidation.
Tools
In regulated industries, teams are strongly advised not to proceed without dedicated tools.
For example, Application Lifecycle Management (ALM) tools help automate requirement tracking, integrate risk assessments, and ensure test traceability.
Other applications manage version delivery and configuration control. Finally, test automation tools can automatically execute regression tests. The traceability of these automated tests must also integrate fully with user requirements and associated risks.
Testing
In Agile mode, validation activities are performed during each iteration and are an integral part of development. Each version must be verified, and testing efforts must be carefully targeted. The strategy should include regression testing to manage the risk of modifying already tested features.
Various test types must be conducted—not only nominal tests to demonstrate correct operation but also boundary and failure tests.
Documentation
Validation documentation is a key component. It must be integrated into the development cycle and updated throughout iterations.
Agile promotes electronic documentation to facilitate dynamic updates of requirements, risks, and tests. Each released application version must be linked to current specification records to ensure modification traceability.
Depending on the tools used, these updates may not involve formal electronic signatures.
Quality Management System
Agile development methods must be included in the company’s Quality Management System (QMS).
A procedure should define how validation fits within the Agile development process, including the use of specific tools and role definitions. The responsibilities of the validation lead and Quality Assurance must be clarified early during planning.
Key success factors
Agility is not, as is sometimes claimed, a method without structure or change control—it can be effectively applied in regulated environments.
A key success factor is the early involvement of Quality Assurance, beginning with the user requirements definition.
At the heart of Agile lies an autonomous, multidisciplinary, and stable team—meaning the same group follows the project from start to finish. Team members should be trained not only in Agile methodology but also in its terminology and collaborative, flexible mindset.
For effective validation, Agile-specific tools are indispensable. They ensure continuous tracking of requirements and risks throughout development.
Implementing Agile often requires organizational transformation. A hybrid mode can serve as a transitional step before adopting full Agile.
Feedback on validation in an Agile project
Positive outcomes include systems that meet user expectations thanks to the flexibility of the approach. Gradual adoption by key users fosters engagement and system acceptance.
A key caution: Agile does not necessarily save time. The time distribution is different. Each iteration involves documentation updates, risk reassessments, and repeated testing. When these updates are neglected, compliance issues arise.
Another caution: test quality. Tests are often linear, verifying only system functionality without proper linkage to identified risks. Boundary and failure tests are insufficiently included.
Finally, Agile has its limits. Flexibility and adaptability must not result in a system that deviates too far from the initial requirements—for reasons of cost, resourcing, schedule, and quality feasibility.
EFOR by your side in Agile mode
EFOR’s VSI experts perform validation activities for your computerized systems independently within both Agile and sequential projects. We apply a methodology tailored to context, integrating risk assessments and documentation aligned with the latest regulatory and technological updates. This proven process, implemented by our experts, ensures compliance of your computerized systems.
EFOR supports you through:
- Participation in system design
- Iterative risk analyses
- Formal test writing during cycles or iterations
- Training on Agile-mode validation in GxP environments
- Test execution support during iterations using the necessary tools and preparation of the validation report