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Praxikon
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Applicablev2.0.0

Article 72: post-market monitoring

Systematic monitoring of high-risk AI in real use, after market placement.

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.

Praxikon tracks Article 72: post-market monitoring under the EU AI Act, checked against the official source on 6 September 2026, citing the source for every statement.

Status
Applicable
Application date
2 August 2026
Version
2.0.0
Last reviewed
6 September 2026

Review status: placed against the official source (6 September 2026). Next check due by 5 March 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

From source to evidence

Why this obligation applies, what it asks of you, and what you show for it.

Applies

Applicable · 2 August 2026

For whom

  • Deployer
  • Provider of an AI system

What you do

Draw up a post-market monitoring plan

What you record

Monitoring plan and reports

Official source

Article 72(1)-(4)

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

This provision is named in none of the three points of Article 113, third paragraph, and therefore falls under the general application date in the second paragraph: 2 August 2026. The move to 2 December 2027 and 2 August 2028 in point (c) concerns only Chapter III, Sections 1, 2 and 3, with the exception of Article 6(5). When a high-risk AI system that this provision addresses can practically exist is a second question: through Article 6(2) and Annex III that is 2 December 2027, and through Article 6(1) and Annex I 2 August 2028. That practical date sits in high_risk_regime_from and not in deadline_at. This is how decision D1 of 6 September 2026 is recorded; see data/ai-act/review/decision-d1-application-dates.json.

Our interpretation

The official source remains authoritative. This general interpretation is not legal advice.

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)

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council | original-oj-2024-07-12

    Source locator: Article 113, second paragraph

  • Digital Omnibus on AI 2026/1744

    European Parliament and Council | official-journal-2026-07-24

    Source locator: Article 1, point (40)(b), replacing Article 113, third paragraph, point (c)

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Article 72: post-market monitoring",
praxikon:eu:ai-act:obligation:article-72-post-market-monitoring@2.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0),
effective_at 2026-07-27T00:00:00.000Z, known_at 2026-09-06T00:00:00.000Z,
sha256 6fe04840ffe25ded5e84488a9486d4fa3f46720b9c66ce47d2244110d9e33098,
https://www.praxikon.com/en/verplichtingen/article-72-post-market-monitoring
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-72-post-market-monitoring&effective_at=2026-07-27&known_at=2026-09-06&lang=en, accessed 2026-09-07)

Short form

praxikon:eu:ai-act:obligation:article-72-post-market-monitoring@2.0.0 (sha256 6fe04840)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-72-post-market-monitoring-2-0-0,
  author       = {{Praxikon}},
  title        = {Article 72: post-market monitoring},
  year         = {2026},
  version      = {2.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-72-post-market-monitoring},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.2.0, schema 1.5.0},
  note         = {effective_at 2026-07-27T00:00:00.000Z; known_at 2026-09-06T00:00:00.000Z; sha256 6fe04840ffe25ded5e84488a9486d4fa3f46720b9c66ce47d2244110d9e33098},
  url          = {https://www.praxikon.com/en/verplichtingen/article-72-post-market-monitoring},
  urldate      = {2026-09-07},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:article-72-post-market-monitoring@2.0.0",
    "type": "dataset",
    "title": "Article 72: post-market monitoring",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "2.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-72-post-market-monitoring",
    "URL": "https://www.praxikon.com/en/verplichtingen/article-72-post-market-monitoring",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          9,
          6
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          7
        ]
      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0; schema 1.5.0; effective_at 2026-07-27T00:00:00.000Z; known_at 2026-09-06T00:00:00.000Z; sha256 6fe04840ffe25ded5e84488a9486d4fa3f46720b9c66ce47d2244110d9e33098; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-72-post-market-monitoring&effective_at=2026-07-27&known_at=2026-09-06&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

How to verify a reference later is set out in the methodology. Terms

What changed in this

Moments when this obligation took effect, moved or received official guidance.

  • 2027-09-02 | upcoming

    Template for the post-market monitoring plan becomes guidance, by 2 September 2027

    Article 72(3) has been replaced. The original text required an implementing act with a template by 2 February 2026, and that deadline had passed without an act. Since 27 July 2026 it is guidance including a template, to be adopted by 2 September 2027. There is therefore no overdue implementing act; anyone waiting for the old template is waiting for something that will not come.

See the full timeline

Version history

  1. v2.0.0

    27 July 2026

    Article 72: post-market monitoring

    Systematic monitoring of high-risk AI in real use, after market placement.

  2. v1.0.0

    27 July 2026

    Article 72: post-market monitoring

    Systematic monitoring of high-risk AI in real use, after market placement.

Corrections to this obligation

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Zahed Ashkara, lawyer and AI governance specialist

Expert behind this page

Zahed Ashkara

Lawyer and AI governance specialist

Execution

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