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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.

  1. 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.

  1. 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

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

  1. 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 approach

For AI agents and integrations

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