The advantage of the U.S. FDA’s effort to regulate artificial intelligence (AI) in medical devices is that it is specific to medical devices and other medical products, but this vertical approach to AI regulation might soon become exceptionally complicated thanks to a new AI risk management framework posted by the U.S. National Institute for Standards and Technology (NIST). The NIST guideline is agnostic to the sector of the economy and thus may carry with it the expectation that developers of software as a medical device will hew to both the NIST framework and FDA regulations, a layering of requirements that could vastly complicate the task of developing and deploying these algorithms.