Post-Market Monitoring (Article 72)
Provider monitoring after market placement
TL;DR
Post-market monitoring (PMM) under Art. 72 EU AI Act (Regulation (EU) 2024/1689) is the obligation on providers of high-risk AI systems to monitor the system continuously after market placement. Content: collecting and analysing performance data, incidents and complaints. The general date of application of 2 August 2026 remains; the high-risk obligations in Chapter III, Sections 1–3 apply to Annex III systems only from 2 December 2027 and to Annex I systems from 2 August 2028 (Regulation (EU) 2026/1744 (Digital Omnibus AI), in force since 27 July 2026).
What is Post-Market Monitoring (Article 72)?
Contents of the PMM plan (Art. 72(1)):
- Monitoring methodology
- Collection mechanisms for performance data
- Reporting frequency
- Triggers for corrective action
- Interface with incident reporting (Art. 73)
Link to Art. 73 (reporting of serious incidents): to the market surveillance authority within 15 days of becoming aware.
Practical example
PMM for an HR recruiting tool:
- Quarterly bias audit (protected characteristics)
- Sample reviews of the recommendations
- Complaints tracking
- Performance drift monitoring