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Document contents qmsWrapper Technical Overview
  1. 1 Architecture & Module Map
  2. 2 Foundation Layer
  3. 3 Design-Cycle Layer
  4. 4 Post-Market Layer
  5. 5 Governance Layer
  6. 6 Cross-Cutting AI Capabilities
  7. 7 What Each Actor Sees
  8. 8 Why This Architecture
  9. 9 Glossary

qmsWrapper Technical Overview · Chapter 8 of 9

Why This Architecture

8. Why This Architecture

Three architectural decisions distinguish Wrapper from the typical SME stack:

1. One Log per regulated artefact, not one folder. Folder-based eQMS answers "show me X" with "open this folder and scroll". Log-based eQMS answers with "open this Log, filter by X, see the signed row". The first fails at every NB audit; the second is what the regulator wants. ISO 13485 §4.2.4 record-retrievability is a clause-level audit criterion.

2. One Audit trail across the entire eQMS. Most eQMS products run separate audit logs per module. Wrapper’s polymorphic ObjectApproval + INSERT-only AuditSignature chain is single-source-of-truth across all seven approvable object types. 21 CFR Part 11.10(e) requires the audit trail to be independent of operator and capable of being copied without altering the original — Wrapper’s INSERT-only DB grants enforce this at the storage layer, not just the application.

3. One AI contract — proposal, not action. Most AI-enabled compliance products allow the AI to autonomously act. This puts those products into High-Risk classification under EU AI Act Annex III + Art. 6. Wrapper’s AI architecture is architecturally HITL: the AI writes findings, humans approve actions, every approval is PIN-signed. This keeps Wrapper’s own AI in the Limited-Risk class (Art. 50 transparency only) while still producing regulator-grade evidence.

These three decisions compound: because every artefact is a Log row, the audit trail is automatic; because the audit trail is unified, the AI proposals can be approved against it; because the AI approvals are PIN-signed into the same trail, the HITL evidence is regulator-defensible.

Frequently asked questions

Why is qmsWrapper log-based instead of folder-based?

A folder-based eQMS answers a regulator request by making you open a folder and scroll, which fails at Notified Body audits. The log-based design lets you open a Log, filter, and see the signed row, satisfying ISO 13485 section 4.2.4 record-retrievability. Because every artefact is a Log row, the audit trail becomes automatic.

Does the qmsWrapper AI act on its own?

No. The AI architecture is human-in-the-loop: the AI writes findings and proposals, humans approve actions, and every approval is PIN-signed. The AI proposes, it never autonomously acts. This keeps the AI in the EU AI Act limited-risk class with transparency obligations only, while still producing regulator-grade evidence.

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