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EU AI Act

AI Act Post-Market Monitoring: Continuous Compliance Infrastructure for Deployed AI Systems

The AI Act requires post-market monitoring of high-risk AI systems. Here's the infrastructure for continuous model monitoring, incident detection, and regulatory reporting.

Luca Berton7 min read

Article 72 of the AI Act requires providers to establish post-market monitoring systems "proportionate to the nature of the AI technologies and the risks of the high-risk AI system." Translation: you need continuous monitoring infrastructure that catches problems before they become incidents.

What to Monitor

Performance Degradation

  • Accuracy metrics tracked against deployment benchmarks
  • Prediction distribution shifts (concept drift, data drift)
  • Latency and throughput degradation
  • Error rate trends by category, geography, and time period

Fairness Drift

  • Continuous fairness metric computation across protected groups
  • Disparate impact ratio monitoring
  • Equalized odds tracking over time
  • Subgroup performance comparison against deployment benchmarks

Safety Signals

  • Edge case frequency — inputs outside training distribution
  • User complaint correlation with model predictions
  • Human override rates — increasing overrides suggest model degradation
  • Adversarial input detection

Alerting and Escalation

Define alerting thresholds tied to AI Act requirements:

  • Warning — Metric approaching threshold, investigate within 24 hours
  • Critical — Metric breached threshold, initiate remediation
  • Incident — Serious risk to health, safety, or fundamental rights — trigger incident response and consider reporting to market surveillance authority (Article 62)
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Serious Incident Reporting

Article 62 requires reporting serious incidents to market surveillance authorities. Your infrastructure must: detect incidents automatically, classify severity against AI Act criteria, generate structured incident reports, and submit within regulatory timelines. This mirrors CRA and DORA reporting — build a unified reporting pipeline.

ai act
post-market monitoring
model monitoring
ai observability
compliance

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18+ years experience · Ex-Red Hat & Dell · Speaker at KubeCon EU 2026

Luca Berton

Written by

Luca Berton

CEO at Open Empower. 18+ years building enterprise infrastructure at JPMorgan Chase, Red Hat & Dell. Author of 9 technical books. Speaker at Red Hat Summit and KubeCon EU 2026. Instructor on Coursera, Pluralsight & Udemy.

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