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EU AI Act Article 72: post-market monitoring for AI agents

Article 72 requires providers of high-risk AI systems to establish and document a post-market monitoring system proportionate to the nature of the AI technology and its risks. The system must actively and systematically collect, document and analyse relevant data on the performance of the system throughout its lifetime, whether provided by deployers or collected through other sources, so that the provider can evaluate continued compliance.

The monitoring is based on a post-market monitoring plan, which is part of the technical documentation (see Article 11). The Commission is to provide a template for it through an implementing act.

What agents make different

A deployed agent meets inputs, tools and other systems its developers never saw. Where relevant, Article 72 explicitly includes analysis of the interaction with other AI systems, which is the normal case for multi-agent setups.

The raw material for monitoring is the run log. Without it, "monitoring" means waiting for complaints.

What to monitor

• Blocked and warned actions per week, by rule. A rise is either a new attack pattern or a model regression.
• Human escalations and how often humans overrode the agent.
• Cost and step count per run, to catch loops and runaway behaviour early.
• Tool error rates, which often precede wrong actions.
• Behavioural drift after model updates, measured by replaying a fixed set of recorded runs and diffing the actions.

Getting data from deployers

Deployers keep the logs (see Article 26). Your plan should say what you ask them to share and in what format. A signed, portable ledger they can export and you can verify without trusting their storage makes that exchange simple.

From monitoring to action

Monitoring feeds risk management: each new failure mode becomes a rule or a test. When a finding is a serious incident, the reporting clock of Article 73 starts.

Check your own logs

Paste a Vetro ledger or an OpenTelemetry GenAI trace export into the free checker: it verifies integrity and shows which record-keeping obligations your evidence covers, in your browser. When you need something to hand to an auditor or a customer, the countersigned EU AI Act report costs 49 USD, one-off: an ed25519 counter-signature over your evidence plus a mapping to the articles, including an explicit list of what the log cannot show.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.