Article 72: post-market monitoring
Systematic monitoring of high-risk AI in real use, after market placement.
The official source remains authoritative. This general interpretation is not legal advice.
- Status
- Upcoming
- Application date
- 2 December 2027
- Version
- 1.0.0
- Last reviewed
- 8 August 2026
Who this is relevant to
When this applies
Deployer
An organisation using an AI system under its authority, excluding personal non-professional use.
Provider of an AI system
A party that develops or has an AI system developed and places it on the market under its own name.
- 1The provider has a high-risk system on the market; deployers supply the real-world data via monitoring and signals.
What the official source establishes
Article 72 obliges providers to operate a post-market monitoring system with a plan forming part of the technical documentation, collecting relevant real-world data to evaluate continued compliance with Section 2.
For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.
Our interpretation
Compliance does not stop at go-live: this article turns compliance into a continuous state. For deployers it is also the basis to force suppliers to act on deviations.
What you can do now
Design the monitoring together with the Article 12 logging: the same data flows feed both duties.
- 01
Draw up a post-market monitoring plan
Systematically collect and analyse real-world data on the system’s performance and compliance throughout its lifetime.
What to retain
Monitoring plan and reports
The plan as part of the technical documentation plus the periodic analyses and follow-up actions.
Control and reassessment
Signal-to-action loop
Ensure real-world signals (deviations, complaints, incidents) demonstrably lead to analysis and, where needed, measures.
Public tools
Full text of Article 72
The full legal text in the public AI Act Explorer.
Conditions and exceptions
- The plan may be proportionate to the nature of the system and align with existing sectoral monitoring regimes.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Article 72(1)-(4)
Digital Omnibus on AI 2026/1744
European Parliament and Council | official-journal-2026-07-24
Source locator: Amended Article 113 application dates
Version history
v1.0.0
27 July 2026
Article 72: post-market monitoring
Systematic monitoring of high-risk AI in real use, after market placement.
Execution
From obligation to arranged and demonstrable
Knowing where you stand is step one. Embed AI translates this obligation into a concrete approach for your organisation: scope, ownership, register and evidence.
See the Embed AI approachFor AI agents and integrations
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