Post-Market Monitoring
High-Risk AI Post-Market Monitoring
What this control does
Operate a proportionate lifecycle post-market monitoring system and plan for high-risk AI.
How to implement
For high-risk AI providers, connect post-market monitoring to the technical file and risk process.
- Define the monitoring plan, responsible owner, data sources and review arrangements for the system's lifetime.
- Collect and analyze relevant performance information, deployer feedback, incidents and other data needed to evaluate continuing compliance. Include relevant interactions with other AI systems.
- Set practical escalation criteria, assign owners to findings and connect them to risk reassessment, investigation or corrective action.
- Review the plan as the system and operating conditions change, retaining evidence of decisions and follow-up. Do not include sensitive operational data of law-enforcement deployers in this collection. Assess any permitted integration with existing sectoral monitoring rather than assuming it removes the AI-specific work.
Suggested timing and triggers
Active monitoring throughout the system lifetime; systematic analysis at defined intervals; immediate escalation where a finding triggers another duty.
Evidence examples
Approved monitoring plan linked to the technical file Data-source, metric and responsibility records Performance analysis and deployer feedback Escalation decisions and linked corrective actions Plan updates and follow-up effectiveness reviews
How to check this control
Select a monitoring period and trace a significant finding into the risk assessment or corrective-action process. Check that the planned data was actually collected and reviewed, and that a closed issue was reassessed where needed.
Related EU AI Act obligations
Article 72
Establish and Maintain Post-Market Monitoring for High-Risk AI
Article 72(2)
Systematically Collect, Document and Analyse High-Risk AI Post-Market Performance Data
Sub-obligation of Article 72: Establish and Maintain Post-Market Monitoring for High-Risk AI
Article 72(3)-(4)
Maintain the High-Risk AI Post-Market Monitoring Plan in Technical Documentation
Sub-obligation of Article 72: Establish and Maintain Post-Market Monitoring for High-Risk AI