Post-Market Monitoring Plan Template
Article 72 post-market monitoring plan for high-risk AI providers, covering monitoring systems, data collection, performance review, and corrective action procedures.
Quick Answer
EU AI Act Article 72 requires high-risk AI providers to maintain a post-market monitoring plan with systematic data collection, performance KPIs, annual reviews, and a feedback loop back into the risk management system.
Compliance Checklist (8 items)
Penalty if not compliant
Up to €20 million or 4% of global annual turnover; authorities may require market withdrawal if monitoring obligations are persistently unmet.
Frequently Asked Questions
Is a post-market monitoring plan required before or after deployment?
Before. The monitoring plan must be in place and described in the technical documentation before the high-risk AI system is placed on the market or put into service.
How long must post-market monitoring data be retained?
There is no single fixed retention period; retention must be appropriate to the risk level and type of data. Technical documentation (including monitoring records) must be kept for at least 10 years.
Who conducts post-market monitoring — provider or deployer?
Providers design and implement the monitoring system. Deployers must share relevant data and feedback with providers. In practice, both have contractual obligations to exchange operational performance information.
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