Compliance question · Survey platformsUpdated October 12, 2026

Is Qualtrics 21 CFR Part 11 compliant for clinical research?

We found no public Qualtrics statement of Part 11 compliance. Part 11 is also not a badge: it depends on controls, validation and how you use the system. Here is what to ask and what to check.

  • No invented claims
  • Part 11 question list
  • Alternatives

Free sandbox · No credit card · 21 CFR Part 11 aligned

Part 11 questions for a survey tool · demo

Answered in writing

0 of 6

  • System validation evidenceAsk vendor
  • Secure, time-stamped audit trail of changesAsk vendor
  • Access limited to authorised users
  • Signatures linked to records, with meaning
  • Unique credentials for each signer
  • Records retained and exportable
A blank worksheet for a vendor reply. Fill it from their documents, not from this page

The short answer

  • We could not find a public Qualtrics statement of 21 CFR Part 11 compliance when we searched on 2026-10-12. Its published compliance material that we found concerned GDPR and data protection. Ask Qualtrics for Part 11 documentation in writing.
  • Part 11 compliance is not a vendor badge. It depends on the system's controls, your validation and your procedures.
  • Qualtrics is a survey platform and is strong for surveys. Clinical records that support regulatory submissions need an audit trail, signature controls, access control and validation evidence.
  • Capture is built with Part 11 aligned controls (field-level audit trail, re-authenticated signatures, role-based access) and a free sandbox so you can check yourself. Part 11 remains a shared responsibility.
  • If the data are not part of a regulated trial, Part 11 may not apply at all. Confirm with your sponsor or institution.

The question

Why people ask whether Qualtrics is Part 11 compliant

Universities license Qualtrics widely, so it is often the first tool teams reach for when a clinical study needs questionnaires. Then a sponsor, an auditor or a data manager asks the Part 11 question, and nobody has the answer. The honest position is that we cannot tell you Qualtrics is compliant, and we cannot tell you it is not. We found no public Part 11 statement from the vendor. What we can do is show what Part 11 asks of an electronic records system so that you can put exact questions to Qualtrics and judge the replies.

Three framing points help. First, Part 11 applies to records that the rule covers, such as those required by FDA predicate rules; a survey that is not trial data may fall outside it. Second, compliance is not certified by the FDA for software; it is demonstrated through validation and procedures. Third, a tool can be excellent for what it was built for and still be the wrong place for regulated trial records. See 21 CFR Part 11 compliant EDC and the Part 11 compliance checklist.

For the broader choice between tools, Capture vs Qualtrics and REDCap vs Qualtrics set out when a survey platform is enough. If you are already using Qualtrics and want to move, read how to migrate from Qualtrics.

What Part 11 asks

Part 11 control areas, what to ask Qualtrics and what Capture provides

Control areas follow the general structure of 21 CFR Part 11 (system controls in 11.10, signatures in 11.50, 11.70 and 11.200). Put each question to Qualtrics in writing; the Qualtrics column is deliberately blank of claims.

Control areaWhat to ask QualtricsCapture
ValidationWhat validation documentation exists, and who holds the validated state for your use?Documentation for sponsor validation and UAT is available to enterprise customers; validated use is a shared responsibility
Audit trailIs there a secure, time-stamped trail of changes with old and new values and reasons that cannot be edited?Field-level, append-only, hash-chained; user, time, old and new value and reason; exportable
Access controlHow is access limited, and can identifiers be separated from analysis roles?Role-based access; site coordinators see names, researchers see coded IDs; row-level security
Electronic signaturesAre signatures linked to records, with printed name, date and meaning?Password re-authentication and a legal meaning statement for staff; eConsent with email one-time code
Record integrityCan a form change mid-study without a trace?Draft and approved states; approved forms locked for live use
Retention and exportCan complete records be exported in readable form?CSV and Excel exports with an automatic data dictionary

The Qualtrics question column is a worksheet, not a finding. Record the vendor's own written answers.

Check the controls yourself

The Capture sandbox has every feature. Change a value with a reason, sign a form and read the audit trail, with no credit card.

See Part 11 controls free

What good looks like

An audit trail a Part 11 reviewer can read

The test is simple: change one value and see what is recorded. A reviewer expects to see who changed it, when, the old and new values and why, and expects that the entry cannot be altered afterwards. Capture records one row per changed field with those details, written by database triggers.

  • One row per changed field; user, timestamp, old value, new value, reason.
  • Append-only: the database blocks updates and deletes to audit rows.
  • Hash-chained rows per study; exportable.
Audit entry · demo
Demo study · Subject 001-0042 · Visit 3Locked row

Field

Systolic blood pressure

Old value

152mmHg

New value

125mmHg

Reason for change

Transcription error corrected from source

Changed by

site.coordinator (001)
Demo audit entry. Real trails are exportable per study

Fit

When Qualtrics may be fine, and when it is not enough

Qualtrics may be a sensible choice for one-off surveys, formative research, recruitment screening or studies whose records are not covered by Part 11, provided your institution and ethics committee agree. Its strengths are survey design, distribution and analysis. See HIPAA-compliant survey tools for research for what to check on privacy.

It is more likely to fall short when the data support a regulatory decision, when a sponsor expects a validated system, or when the study needs visit schedules, site-entered data, adverse events, randomization or verified consent signatures. In that case use a clinical study platform. Capture is suitable for Phase 1, 2 and 3 and has a free sandbox. It does not work offline, and Part 11 remains a shared responsibility whichever product you choose.

Evaluation checklist

Before you rely on any tool for regulated trial records

Confirm Part 11 applies

Ask your sponsor, regulatory affairs or ethics contact which records are covered.

Get the vendor reply in writing

Validation, audit trail, signatures and access control, with documents attached.

Test one change end to end

Edit a value with a reason; export the trail. See audit trail software.

Define the validation path

Who writes and holds the evidence. See computer system validation.

Check signatures

Re-authentication and meaning. See electronic signatures for clinical trials.

Plan the exit

Export data and a dictionary and archive them with the study documents.

FAQ

Questions teams ask before they switch

Something not covered here? Ask us directly.

Is Qualtrics 21 CFR Part 11 compliant?

We found no public Qualtrics statement of Part 11 compliance when we searched on 12 October 2026. Ask Qualtrics for written documentation covering validation, audit trail, signatures and access control, and do not assume compliance.

Does Part 11 apply to every survey?

No. Part 11 applies to electronic records and signatures covered by FDA predicate rules. A survey outside a regulated trial may not be covered. Confirm with your sponsor or institution.

Can software be certified Part 11 compliant?

Not by the FDA. Compliance is demonstrated through the system's controls, validation and your procedures. Be cautious of badges.

Is Capture Part 11 compliant?

Capture provides Part 11 aligned controls: a field-level audit trail, re-authenticated electronic signatures and role-based access. Compliance is a shared responsibility with the sponsor's validated use.

Can I use Qualtrics for a clinical trial?

Only if the records are not covered by Part 11 or your sponsor accepts it after review. For regulated data, use a clinical study platform with validation evidence.

Can I move a Qualtrics survey into Capture?

Upload an export of the survey or describe it, review the AI draft, add codes, edit checks and a schedule. See the migration guide.

Does Capture work offline?

No. Offline entry is not available today.

How do I try Capture?

Open the free sandbox, with every feature and no credit card. You pay only when you go live.

See Part 11 aligned controls in a sandbox

Free, every feature, no credit card. Change a value, sign a form and read the audit trail yourself.

See Part 11 controls free