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
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
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.
- 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)
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.
Version history
v2.0.0
27 July 2026
Article 72: post-market monitoring
Systematic monitoring of high-risk AI in real use, after market placement.
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
No substantive correction to this object has been recorded.
Open the correction logExecution
From obligation to arranged and demonstrable
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