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Post-market monitoring and continuous improvement of AI: how to watch your systems once live

Launching an AI system is not the end of the work: it is the start. Models degrade, data changes and uses appear that nobody foresaw. Post-market monitoring is the orderly way to find out in time and improve.

What the AI Act says

  • Art. 72, post-market monitoring: providers of high-risk systems must set up a proportionate system to collect and analyze data on the system’s performance throughout its lifetime. It forms part of the technical documentation.
  • Art. 73, serious incidents: the provider must report a serious incident to the authority after establishing the link with the system, and within 15 days at most. The deadline drops to 2 days for a widespread infringement or a serious incident in critical infrastructure, and to 10 days in case of death.
  • Art. 26, deployers: must monitor operation according to the instructions for use and inform the provider and the authority if they identify risks or serious incidents.

Even if you are only a user of a system, monitoring it is what lets you meet your part. More on how to react in AI incidents.

What to watch

  • Answer quality: hits, errors and hallucinations in a sample reviewed by people.
  • Drift: changes in data or behavior that make the model perform worse than on launch day.
  • Fairness: whether results differ unjustifiably between groups of people.
  • Complaints from users or affected people.
  • Actual use: who uses it, for what, and whether it strays from the intended purpose.
  • Incidents and near misses, even when they are not serious.

A simple continuous improvement cycle

  1. Define indicators with an alert threshold for each system (for example, a maximum share of incorrect answers in the sample).
  2. Measure at fixed intervals: monthly or quarterly depending on risk.
  3. Analyze and decide: fix, retrain, restrict use or retire?
  4. Record the finding, the decision and who made it.
  5. Report to management with a periodic review of results and risks.
  6. Update the inventory, classification and documentation if anything changes.

How it fits with ISO 42001

ISO/IEC 42001 follows a “plan, do, check, act” logic: performance evaluation (measuring, internal audit and management review) and improvement (correcting and improving continually) are central parts. If you are working towards it, this monitoring is part of that path; see the certification checklist and the article on internal AI audits.

Common mistakes

  • Measuring once, at launch, and never looking again.
  • Indicators with no threshold or owner: nobody acts when they drift.
  • Not keeping evidence of the reviews.
  • Leaving monitoring to the technical team alone, without it reaching management.

Frequently asked questions

Is it mandatory if my system is not high-risk?

Art. 72 applies to high-risk systems. But monitoring any system that affects people or decisions is good practice and makes it easier to show diligence.

How often should I review?

It depends on risk and speed of change. Monthly for sensitive systems, quarterly or half-yearly for the rest.

What is a serious incident?

Broadly, one that causes or may cause death or serious harm to health, critical infrastructure, fundamental rights or property. The exact definition is in Art. 3 of the Regulation.

Informational content, not legal advice. AI regulation changes quickly: always check the current official text before deciding. Information reviewed as of October 15, 2026.

Want to watch your models for drift? Drift Detection and Monitoring Plan: what to measure, thresholds, frequency and response when something drifts. €29. Support template, not legal advice.
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This gives you the method. If you want the finished template: Drift Detection and Monitoring.

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