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Article 72 — Post-market Monitoring System

Providers must establish a documented post-market monitoring system to actively collect, document and analyse data on the AI system's performance throughout its lifetime.

Audit-survivable
19%
of 50 EU-exposed enterprises in MindMap's 2026 readiness benchmark

What the Article requires

Article 72 requires providers to establish a post-market monitoring system proportionate to the risks of the high-risk AI system. The system must actively and systematically collect, document and analyse relevant data on the AI's performance after placing-on-market, evaluate continuous compliance with Articles 8-15, and feed back into corrective actions. Implementing acts may further specify the monitoring requirements per use case.

In engineering terms

The lowest-scoring Article on MindMap's 50-enterprise readiness benchmark (19% audit-survivable). Most customers have not built the operational substrate for AI-specific post-market monitoring. The fix is a Langfuse-or-equivalent observability layer with structured drift detection, an incident-and-near-miss registry, and a periodic review cadence (typically monthly) feeding into corrective-action workflows.

Compliance checklist

  • ✓Observability platform deployed (Langfuse self-hosted or equivalent)
  • ✓Drift-detection rules per AI system
  • ✓Incident and near-miss registry with workflow
  • ✓Monthly performance-review cadence
  • ✓Corrective-action workflow with audit trail

Terms used here

EU AI ActAnnex III high-risk AI

All Articles in the reference · The EU AI Act compliance architecture

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