For Heads-of · Practitioner
Post-Market Monitoring
A provider's documented, continuous collection and analysis of data on how its high-risk AI system performs once in use, so that problems are found and fixed throughout the system's life. It is the legal form of model monitoring under the EU AI Act.
- EU AI Act
- Article 72
- monitoring
- high-risk AI
- providers
What the Act requires
Article 72 requires providers of high-risk systems to set up a post-market monitoring system, proportionate to the risks, based on a written plan that forms part of the technical documentation. It must actively collect and analyse data on the system's performance throughout its lifetime, including data deployers provide, so the provider can check continued compliance. The 2026 Digital Omnibus replaced a planned implementing act with Commission guidance, including a template for the plan, due by 2 September 2027.
How it connects
Post-market monitoring feeds serious incident reporting (Article 73), corrective action and the next version of the system; see AI incident. Deployers contribute through their own duty to monitor operation and report problems to the provider. For a deployer the practical equivalent is model monitoring.
What good looks like
Define what will be monitored, and the thresholds that trigger action, before release; agree with deployers what data they will share; and close the loop so that findings change the system, its documentation or its instructions for use. The register entry is AI model drift and degradation; AI system monitoring and logging is the control.
Sources
Related Terms
AI Incident
An event in which the development, use or malfunction of an AI system directly or indirectly leads to harm to people's health, critical infrastructure, rights, property, communities or the environment. An AI hazard is an event that could plausibly have led to one. Reporting regimes in the EU and several US states now attach legal deadlines to the most serious cases.
Conformity Assessment
The procedure by which the provider of a high-risk AI system shows that it meets the EU AI Act's requirements before placing it on the market. For most high-risk systems it is an internal control the provider carries out itself; for some biometric systems it needs a notified body.
High-Risk AI System
An AI system that the EU AI Act subjects to its full set of requirements, either because it is a safety component of a product covered by EU product law (Annex I) or because it is used in one of eight listed areas (Annex III), which include credit scoring and life and health insurance pricing. Since the 2026 Digital Omnibus the obligations apply from 2 December 2027 for Annex III systems and 2 August 2028 for Annex I systems.
Model Monitoring
Continuous observation of a deployed model's inputs, outputs, performance and behaviour, to detect degradation, drift, misuse or security anomalies.