Topic 04 · AI & software · Deep dive

A thousand clearances, one paid code: the strange economy of imaging AI

Radiology owns medical AI on paper: 1,104 of the 1,451 AI-enabled devices the FDA has ever authorised — 76% — belong to imaging. But regulatory clearance has run far ahead of evidence, reimbursement, and daily use. As of 2025 exactly one imaging-AI application held a paid CPT Category I code, and where the tools are genuinely deployed at population scale, the results are only now arriving.

1,104
FDA-authorised AI-enabled radiology devices through end-2025 — 76% of all cleared medical AI (1,451 total since 1995)
FDA list / The Imaging Wire, 2026
1
paid CPT Category I code for imaging AI as of 2025 (FFR-CT). A second — coronary plaque analysis — converted on 1 Jan 2026. Both are cardiac CT
ACR CPT advisor / RSNA 2025
48%
of European radiologists were actively using AI in 2024, up from 20% in 2018; a further 25% were planning to
ESR / EuroAIM survey 2024
−44%
screen-reading workload in the MASAI randomised trial of AI-supported mammography screening — with 29% more cancers detected
Lancet Digit Health 2025
The clearance curve

From 6 devices a year to 295: regulation was never the bottleneck

The FDA cleared its first radiology AI in 1998 (ImageChecker mammography CAD). It took two decades to reach 500 total AI devices — and three more years to nearly triple that. Radiology's share has stayed locked around three-quarters throughout.

Cumulative FDA AI-enabled devices, all specialties

Snapshots from successive FDA list updates.
Start of 2023~500 devices · 25 years to get here
~500
May 2024list update
882
September 2025radiology alone passes 1,000
1,356
December 2025latest update
1,451
Source: FDA AI-enabled medical device list via The Imaging Wire (2024–2026) and healthHQ (May 2024 update). Annual clearances rose from 6 in 2015 to 295 in 2025 (Innolitics). Note the list counts devices, including imaging hardware with embedded AI — not just standalone software.

Radiology's share of FDA AI clearances

Percent of authorisations, by year of clearance.
2023peak share
80%
2024168 ML Class II devices cleared
73%
202555 of 72 in Q4 alone
75%
All-time (1995–2025)1,104 of 1,451 devices
76%
Sources: FDA list via The Imaging Wire (2026); JMIR/PMC analysis of 2024 clearances (radiology 74.4%, cardiovascular 6.5%, neurology 6.0%). Nearly all devices enter via the 510(k) substantial-equivalence pathway (94.6% in 2024); median review time was 142 days in 2025, with a quarter cleared in under 90.
1998: where it started
The first cleared radiology AI on the FDA's list is ImageChecker, R2 Technology's mammography CAD (later Hologic) — a lineage that means today's clearance boom is CAD's second act, not its first.
6 → 295 per year
Annual FDA AI/ML clearances grew ~50-fold between 2015 and 2025. In 2025, 221 distinct manufacturers received at least one clearance — 183 of them exactly one. Only 9 companies managed four or more.
Foundation models arrive
In January 2026 Aidoc secured a foundation-model-powered clearance — a single body-CT triage tool covering 14 conditions (aortic dissection, appendicitis, bowel obstruction and others). The FDA is now working out how to tag foundation-model and LLM-based devices on its list.
Who holds the clearances

Modality giants at the top, a long tail of one-clearance startups below

Radiology AI authorisations by company

Cumulative FDA clearances through end-2025, including acquisitions.
GE HealthCareincl. Caption Health, MIM, icometrix
120
Siemens Healthineersincl. Varian
89
Philipsincl. DiA, TomTec
50
Canonincl. Vital Images, Olea
45
United Imagingled 2025 with 10 clearances
38
Aidoclargest pure-play AI vendor
31
DeepHealthincl. Quantib, iCAD
28
Source: FDA list via The Imaging Wire (March 2026). The leaderboard is dominated by equipment vendors clearing AI embedded in scanners and workstations — a reminder that "cleared devices" ≠ "standalone diagnostic algorithms." Radiological CAD alone (product code QIH) accounted for a quarter of all 2025 AI/ML clearances (Innolitics).
Europe: the CE-marked market

Fewer products, and an evidence base growing slower than the catalogue

The Radboud-founded Health AI Register (formerly aiforradiology.com) has tracked the European market since 2020. Its two landmark reviews measure both the market's growth and its persistent weakness: most published validation never rises above technical accuracy.

CE-certified radiology AI products & vendors

Products on the register meeting review inclusion criteria.
Products · 2020van Leeuwen et al.
100
Products · 2023follow-up review
173
Vendors · 2020
54
Vendors · 2023
90
Sources: van Leeuwen et al., Eur Radiol 2021; follow-up review, Eur Radiol 2025. A 2025 EJRAI comparison put the totals at roughly 777 US-authorised radiology AI devices against ~200 CE-marked counterparts — different registers, different counting rules, same order-of-magnitude gap.

How much evidence sits behind the products

Share of CE-marked products, by level of published validation.
Any peer-reviewed evidence · 2020
36%
Any peer-reviewed evidence · 2023639 papers, up from 237
66%
Higher-level evidence · 2023clinical / outcome / economic impact
~24%
Demonstrated clinical impact · 202018 of 100 products
18%
Sources: Eur Radiol 2021 & 2025 reviews (hierarchical model of efficacy). Validation is improving in volume but not in level: the share of papers demonstrating clinical, patient-outcome or socio-economic impact stayed flat at ~24%. On the US side, a scoping review of 692 FDA devices (1995–2023) found only 3.6% reported the race/ethnicity of validation cohorts.
Reimbursement

The pathways that pay — and why most algorithms will never qualify

US Medicare remains the world's reference market for paying for imaging AI, and its verdict so far is stark: clearance is table stakes, payment requires outcome evidence, and outcome evidence is rare.

PathwayWhat it isImaging AI so farNotes
CPT Category IPermanent paid code; requires FDA status, strong evidence, widespread use1 (2025) → 2 (2026)FFR-CT; coronary plaque analysis on CCTA converted 1 Jan 2026. Both cardiac CT
CPT Category IIITemporary "T-codes" for emerging tech; tracking, generally unpaidManyFive years to convert to Category I or lapse; most imaging AI sits here
NTAP (inpatient)Add-on payment above the DRG, max 3 years~8 AI products historicallyFirst: Viz.ai LVO triage (FY2021). FY2025: obstructive-hydrocephalus triage, capped at $241.39/case
TCETTransitional coverage for FDA Breakthrough Devices≤5 candidates/yrCMS targets a national coverage determination within 6 months of authorisation
Proposed: S.1399Health Tech Investment Act — dedicated Medicare pathway for cleared AIBill (2025)Five-year transitional payment; introduced April 2025, not enacted

Compiled from the AMA CPT framework as described in npj Digital Medicine (2024), RSNA 2025 reporting via Radiology Business, EJRAI (2025), and vendor/CMS documentation. The "~8" NTAP count is an approximate historical tally (Cortechs.ai, 2022-era), not a current census — NTAPs expire by design.

Why most will never be paid
CPT codes describe distinct procedures. Detecting fractures, nodules or incidentals is already inside the paid interpretation — the ACR's CPT advisor argues separate codes for that work would mean paying twice. ROI must come from throughput, not fee schedules.
The bar that two tools cleared
FFR-CT and CCTA plaque analysis earned Category I status the slow way: years as T-codes plus outcome trials showing added diagnostic value beyond the underlying scan. Both create new information no radiologist reports unaided.
Europe has no pathway at all
The EU leads on regulation (MDR, AI Act) but has no unified reimbursement route — adoption rides on hospital budgets and national innovation funds, and the AI Act's high-risk obligations land in 2026–27.
The adoption gap

Cleared ≠ paid ≠ used: three numbers that don't rhyme

The funnel, end-2025 (log-scale territory)

From regulatory clearance to routine payment. The small bars are real values.
FDA-cleared radiology AI devicescumulative, 1995–2025
1,104
With any Medicare payment routeestimate · CPT/NTAP/MAC listings
~12*
Paid CPT Category I codesas of 2025 · both cardiac
1
*Modelled order-of-magnitude figure compiled from Ventra Health's April 2025 pathway tracker, historical NTAP approvals, and CPT III→I conversions; there is no official census of "reimbursed AI." The 1,104 and 1 are hard counts (FDA; AMA CPT via RSNA 2025 reporting).

Radiologists who say they use AI clinically

Self-reported use in member surveys — read the caveats below.
Europe · ESR 2024274 of 572 respondents
48%
Italy · 2024 surveydaily use; only 30% of users call it decisive
36%
US · ACR membersearlier survey wave
30%
Europe · ESR 2018same survey series
20%
Sources: EuroAIM/EuSoMII ESR survey, Insights into Imaging 2024 (2% response rate — likely enriched for AI-interested members); Eur J Radiol 2024 Italian survey; ACR figure as cited by Precedence Research 2025. Self-selection means all of these are best read as upper bounds.

Where AI is genuinely deployed, the effect sizes are real

Population-scale mammography screening — the best-evidenced use case in all of imaging AI. Mixed metrics; each bar labelled.
MASAI · screen-reading workloadRCT, Sweden · 105,934 women
−44%
MASAI · cancer detection6.4 vs 5.0 per 1,000; no rise in false positives
+29%
PRAIM · cancer detectionreal-world, Germany · 463,094 women
+17.6%
Sources: MASAI trial, Lancet Digit Health 2025 (final interval-cancer results, Lancet 2026: non-inferior interval-cancer rate, higher sensitivity, same specificity); PRAIM implementation study, Nature Medicine 2025 (6.7 vs 5.7 cancers per 1,000, recall rate unchanged). PRAIM was observational — radiologists chose whether to use AI, a selection-bias risk its authors flag.

Regulation was never the bottleneck

The favourite statistic of every imaging-AI pitch deck — radiology's three-quarter share of all cleared medical AI — is true, and it is also the least informative number in this topic. The 510(k) pathway, through which nearly 95% of these devices pass, requires substantial equivalence to a predicate, not proof of patient benefit; median review took 142 days in 2025, and a quarter of submissions cleared in under 90. The result is a register that grew from roughly 500 devices at the start of 2023 to 1,451 by the end of 2025, in which equipment giants clearing embedded reconstruction and workflow modules sit beside 183 single-clearance startups. Counting clearances measures regulatory throughput. It does not measure clinical AI.

A register is not an evidence base

The Radboud group's longitudinal reviews of the European market are the closest thing the field has to an audit, and they show a catalogue outrunning its footnotes: products up 73% between 2020 and 2023, peer-reviewed validation up from 36% to 66% of products — but the share of evidence demonstrating actual clinical, outcome, or economic impact stuck at about a quarter. The US picture is harsher still: across 692 FDA-cleared devices from 1995–2023, 3.6% reported the race or ethnicity of their validation cohorts. For a purchaser, the practical implication is that the burden of local validation still sits with the buyer, which is exactly the cost the clearance count invites you to forget.

One paid code

The reimbursement funnel is this topic's honest headline. Of more than a thousand cleared radiology devices, exactly one held a paid CPT Category I code in 2025 — FFR-CT — with coronary plaque analysis joining it in January 2026. Both are cardiac CT applications that generate genuinely new information, validated through years of outcome trials while parked as temporary Category III codes. The ACR's own CPT advisor is blunt about the rest: fracture, nodule and incidental-finding detectors describe work already inside the paid interpretation, and coding them separately would mean paying twice. That leaves throughput, triage value, and add-on programmes like NTAP — capped, in the FY2025 hydrocephalus example, at $241.39 per inpatient case and expiring within three years — as the business case for nearly the entire catalogue.

Where it is used, it works — which sharpens the question

The strongest counterweight to the scepticism above is mammography screening, now the best-evidenced deployment in imaging AI. The MASAI randomised trial cut screen-reading workload 44% while detecting 29% more cancers — predominantly small, node-negative invasive disease — and its 2026 interval-cancer results confirmed non-inferiority with higher sensitivity. Germany's PRAIM study replicated the direction of effect across 463,094 real-world screens. Yet self-reported clinical use sits at 48% among surveyed European radiologists and around 30% in older US data, with response rates low enough that both are upper bounds. The gap between 1,104 clearances and this thin band of proven, adopted, and (rarely) paid applications is the defining statistic of radiology AI in 2026 — and the reason clearance counts should never be quoted as adoption.

On the data. The FDA list counts devices, not products: imaging hardware with embedded AI is included, vendor suites are sometimes split and sometimes bundled, and totals shift retroactively as the list is curated. Health AI Register counts are vendor-supplied with different inclusion criteria, so US and EU figures are not directly comparable. The "~12 with a Medicare payment route" figure is a modelled order-of-magnitude estimate, not an official census. Survey adoption numbers carry severe self-selection risk (the ESR survey's response rate was 2%), and the ACR 30% figure predates the current survey cycle. PRAIM was observational with radiologist-elected AI use. All figures span 2020–2026 vintages as labelled.

Sources

  1. FDA — Artificial Intelligence-Enabled Medical Devices (official list)
  2. The Imaging Wire, March 2026 — end-2025 list update (1,451 total; 1,104 radiology; vendor leaderboard)
  3. The Imaging Wire, December 2025 — radiology passes 1,000 clearances
  4. Innolitics — 2025 year in review of AI/ML 510(k) clearances (295/yr, 142-day median, 221 manufacturers)
  5. ML-enabled devices authorized by FDA in 2024 — pathways, specialty split, transparency reporting (PMC)
  6. van Leeuwen et al., Eur Radiol 2021 — 100 CE-marked products and their scientific evidence
  7. Eur Radiol 2025 — 173 CE-certified products, follow-up evidence review
  8. Health AI Register (formerly aiforradiology.com) — live CE-marked product database
  9. Radiology Business, RSNA 2025 — ACR CPT advisor on why reimbursement lags clearance
  10. npj Digital Medicine 2024 — reimbursement pathways (CPT, NTAP, TCET) for radiology AI
  11. EJR AI 2025 — US vs EU regulatory & reimbursement comparison (incl. FY2025 NTAP; S.1399)
  12. Ventra Health 2025 — tracker of radiology AI with Medicare/commercial payment routes
  13. EuroAIM/EuSoMII ESR survey 2024, Insights into Imaging — 48% of respondents using AI
  14. MASAI trial, Lancet Digital Health 2025 — +29% detection, −44% screen-reading workload
  15. PRAIM study, Nature Medicine 2025 — real-world AI mammography screening, 463,094 women