Maintaining a post-market monitoring plan that documents | AIGP
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Maintaining a post-market monitoring plan that documents: Which ongoing disclosure obligation is specifically

AIGP Understanding How to Govern AI Development Medium

A post-market monitoring plan documents how a deployed high-risk system's real-world performance and emerging risks will be tracked after release.

The question

A provider has placed a high-risk AI system on the market and must continue meeting transparency obligations as the system operates. Which ongoing disclosure obligation is specifically directed at documenting how the system will be tracked after it is in use?

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  1. Publishing a detailed summary of the content used to train the system so downstream parties can understand the provenance of its underlying training data.
    Plausible because training-data summaries are a genuine transparency duty, but they apply to general-purpose models and describe training content, not post-deployment tracking.
  2. Maintaining a post-market monitoring plan that documents how the system's real-world performance and emerging risks will be tracked after deployment.
    Correct because a post-market monitoring plan is the transparency artifact specifically covering how a deployed system's performance and risks are tracked over its operational life.
  3. Registering the organization's data protection officer with the supervisory authority so a named contact exists for privacy inquiries about the system.
    Plausible because DPO arrangements support privacy governance, but they concern data-protection contacts, not the post-market monitoring of an AI system's performance.
  4. Filing the system's environmental sustainability metrics with regulators so the compute and energy footprint of its operation is publicly accounted for.
    Plausible because sustainability reporting is an emerging expectation, but it is not the transparency obligation aimed at tracking a deployed system's performance and risks.
The trap
Confusing GPAI training-data summaries or privacy/DPO duties with the post-market monitoring plan that documents post-deployment tracking.

How to remember it

A post-market monitoring plan documents how a deployed high-risk system's real-world performance and emerging risks will be tracked after release.

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