Skip to content

GxP Compliance

Configure GxPSign for FDA 21 CFR Part 11 and other regulatory compliance.

Built to the stricter EU Annex 11 (2025 draft revision)

GxPSign adheres to the tightened e-signature requirements in the EU GMP Annex 11 draft revision, not just the legacy 2011 text:

  • Fresh re-authentication for every signature event — § 13.3 (the existing logged-in session is not accepted).
  • Passkey / biometric authentication — § 11.3, with the AAGUID, credential ID, and userVerified flag recorded per signature.
  • MFA on remote critical systems — § 11.6, satisfied intrinsically by WebAuthn (possession + inherence).
  • Smart card or PIN alone rejected — § 13.3.
  • Cloned-credential detection — strictly-monotonic sign-counter check on every assertion.
  • Signing-event audit trail — § 12.2, with the authenticator method, device model, and verification flags as queryable columns (not buried in JSON metadata).

See the Regulatory Mapping table below for the per-clause crosswalk against 21 CFR Part 11.

What is GxP?

GxP refers to "Good Practice" regulations in life sciences:

  • GMP - Good Manufacturing Practice
  • GLP - Good Laboratory Practice
  • GCP - Good Clinical Practice

GxPSign is designed to meet GAMP5 Category 4 requirements for computer systems used in regulated environments.

Enabling GxP Mode

GxP compliance features are available to all organizations — there is no plan upgrade required. Any organization can enable GxP mode and complete the formal qualification process.

Prerequisites

Before enabling GxP compliance:

  1. Configure a signing certificate
  2. Train users on compliance requirements
  3. (Optional) Purchase SignatureManager seats for users who will create GxP-critical signature requests

Enable GxP Compliance

  1. Go to Settings > Organization
  2. Find GxP Settings
  3. Check Enable GxP Compliance
  4. Select your Qualification Status
  5. Click Save

Screenshot Coming Soon

Screenshot of GxP settings will be added here.

GxP Features

When GxP mode is enabled, the following features activate:

Signature Meaning Required

Every signature must include a meaning:

Meaning FDA Requirement
I have reviewed and approved Approval signature
I attest to the accuracy Data verification
I have performed the work Work completion
I have witnessed the activity Witnessing
I have verified the information Verification
I authorize the release Authorization

Enhanced Audit Trails

All actions are logged with:

  • User identity
  • Timestamp (server time)
  • IP address
  • User agent
  • Action description
  • Before/after values for changes

Re-Authentication

Configurable password re-entry for:

  • Multiple signatures in a session
  • Sensitive operations
  • Extended sessions

Document Integrity

  • SHA-256 hash calculated on upload
  • Hash verified before signing
  • Digital signatures with timestamps
  • Long-term validation (LTV) data

Qualification Status

Qualification Levels

Status Description
Not Qualified System not yet validated
IQ Completed Installation Qualification done
OQ Completed Operational Qualification done
PQ Completed Performance Qualification done
Fully Qualified All qualifications complete

Setting Qualification Status

  1. Go to Settings > GxP Settings
  2. Select the appropriate Qualification Status
  3. Click Save

Documentation Required

Maintain qualification documentation separately. GxPSign tracks status but doesn't generate qualification documents.

Re-Authentication Settings

Purpose

Re-authentication ensures the person signing is who they claim to be, even in shared computer environments.

Configuration

  1. Go to Settings > GxP Settings
  2. Enable Re-authentication Required
  3. Set Timeout Minutes (default: 15)
  4. Click Save

How It Works

  1. User signs their first document normally
  2. Authentication is cached for the timeout period
  3. For additional signatures within timeout: no re-auth needed
  4. After timeout expires: password re-entry required
Environment Timeout
Shared workstations 5-10 minutes
Personal computers 15-30 minutes
High-security 0 (always re-authenticate)

21 CFR Part 11 Compliance

Electronic Signatures

GxPSign provides:

Requirement Implementation
Unique to one individual Email-based identity
Not reused or reassigned User accounts are unique
Contain identifying information Signature includes name, date, meaning
Only used by genuine owner Password-protected accounts

Electronic Records

GxPSign ensures:

Requirement Implementation
Accurate and complete copies PDF documents with all signatures
Protected throughout retention Encryption at rest and in transit
Limited system access Role-based access control
Audit trails Comprehensive event logging
Sequence of entries Immutable, timestamped records

Controls

Requirement Implementation
Operational checks Validation of signature authority
Authority checks Role-based permissions
Device checks Re-authentication requirements
Personnel qualifications Training status tracking

Document Types

GxP Critical Documents

Documents that directly impact product quality or patient safety:

  • Batch records
  • Deviation reports
  • CAPA documents
  • Validation protocols
  • Release certificates

Settings:

  • Signature meaning required
  • Full audit trail
  • Re-authentication (if enabled)
  • Long-term archival

GxP Non-Critical Documents

Documents with less regulatory impact:

  • Meeting minutes
  • Training records
  • General procedures

Settings:

  • Signature meaning required
  • Audit trail maintained
  • Standard retention

Audit Trail

Accessing Audit Logs

  1. Go to Settings > Audit Log
  2. Filter by date, user, or action type
  3. Export as needed

Logged Events

Event Details Captured
Sign-in/Sign-out User, time, IP, success/failure
Document upload User, time, file hash, metadata
Document view User, time, document ID
Signature applied User, time, meaning, field ID
Request created User, time, document, signers
Settings changed User, time, old value, new value

Audit Log Protection

  • Logs are append-only (cannot be modified)
  • Logs are retained according to policy
  • Access to logs is controlled by role

Training Management

Training Status

Track user training status:

  1. Go to Settings > Users
  2. Click on a user
  3. Update Training Status

Training Statuses

Status Meaning Action Needed
Pending Not started Schedule training
In Progress Currently training Monitor completion
Completed Training verified None
Expired Renewal needed Schedule refresher

Training and Signing

Best Practice

Consider preventing users with "Pending" or "Expired" training from signing GxP-critical documents.

Validation Support

System Validation

GxPSign provides supporting documentation for validation:

  • Functional specifications
  • User requirements
  • Test protocols
  • Traceability matrix

Contact support for validation packages.

Ongoing Validation

Maintain validation through:

  • Regular system reviews
  • Change control procedures
  • Periodic testing
  • User training updates

Best Practices

  1. Enable early - Set up GxP mode before production use
  2. Train users - Ensure all users understand compliance requirements
  3. Document everything - Maintain qualification and validation records
  4. Regular audits - Review audit logs periodically
  5. Keep training current - Track and update training status
  6. Test re-authentication - Verify timeout settings work as expected
  7. Review access - Regularly audit user permissions

Signing Re-authentication Policy

GxPSign provides three re-authentication paths at signing time. Selection is automatic based on the user's enrolled credentials and your tenant policy.

Methods

Method What the signer sees Annex 11 alignment
WebAuthn (passkey) One biometric tap on their device (Touch ID / Face ID / Windows Hello / Android / security key). § 11.3 (biometric), § 11.6 (intrinsic MFA via possession + inherence)
Local password Re-enters their account password. § 11.3 (password)
SSO step-up Popup re-runs OIDC sign-in with prompt=login against the IdP. § 11.3 (equivalent to login security), § 13.3

Smart card alone, PIN alone, and "rely on the existing session" are never accepted (§ 13.3).

Tenant Setting: webauthn_required

In your Organisation Settings → Security:

webauthn_required Effect
False (default) Signers may use passkey (preferred), password, or SSO step-up — whichever they have available.
True Passkey is the only accepted method. Signers without an enrolled passkey are sent to set one up before they can sign. Password and SSO step-up fallbacks are disabled for your tenant.

The sending tenant's policy applies. If a signer from Org A signs a request created by Org B, Org B's webauthn_required setting governs the event — not Org A's.

Per-Signature Re-authentication

Effective for all GxP-enabled tenants: every signature event requires a fresh re-authentication. There is no time-window during which subsequent signatures skip the prompt. With WebAuthn, this is a sub-second biometric tap, so the operational cost is minimal while compliance with EU Annex 11 § 13.3 is unambiguous.

Audit Trail Fields

For every signing event, the following are recorded in SignatureAuditLog:

Field What it captures
authenticator_method password, webauthn, or sso_step_up
webauthn_credential_id The exact passkey used (raw FIDO2 credential ID)
webauthn_aaguid Authenticator model (e.g. Apple Touch ID, YubiKey 5) — answers "what device?"
webauthn_user_verified The WebAuthn userVerified flag (always true under our policy — userVerification=required)
webauthn_sign_count Authenticator-reported counter; verified strictly-monotonic to detect cloned credentials

These columns are queryable directly (not buried in JSON metadata), so inspectors can ask "show me all signatures applied with a non-platform authenticator last quarter" and the answer is one SQL query.

Cloned-credential Detection

WebAuthn authenticators advertise a sign counter that must increase on each use. GxPSign refuses any assertion whose counter does not strictly advance and emits a failed_reauth security audit event. This is the FIDO2-spec recommended clone-detection check.

Regulatory Mapping

Capability EU Annex 11 (Draft) 21 CFR Part 11
Fresh per-signature re-auth § 13.3 § 11.200(a)(1)
Biometric / passkey accepted § 11.3 § 11.200(a)(2) (biometric exception)
MFA on remote critical systems § 11.6
Signing-event audit trail § 12.2 § 11.10(e)
Smart-card / PIN alone insufficient § 13.3