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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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The EU AI Act Readiness Kit puts this checklist, and the other 13 Articles', into one fill-in PDF with room for an owner, evidence location and target date on every item. Plus an AI system inventory, a classification record, an Annex IV outline and a FRIA template.

  • 01How to use this kit. Four steps, and which checklists apply to each classification result.
  • 02AI system inventory. One row per AI system: owner, what it does, built or bought, your role and its classification.
  • 03Classification record. The five questions from our applicability checker, with space for answers, notes and the result.
  • 04Evidence checklists. 72 evidence items across Articles 9 to 15, 25, 26, 27, 50, 53, 55 and 72, each with an owner, evidence location and target date.
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