§25 Post-Market Monitoring¶
Version: v3.0
Defines the rcan-incidents-v1 schema — a persistent, append-only incident log for EU AI Act Art. 72 post-market monitoring obligations.
Overview¶
EU AI Act Art. 72 requires providers of high-risk AI systems to actively monitor performance after deployment and report serious incidents to relevant national authorities. RCAN §25 defines a machine-readable incident log format (JSONL) and report schema that support this obligation.
Reporting deadlines: Incidents with severity life_health must be reported within 15 days. All other incidents within 90 days. Both deadlines are surfaced in the generated report under reporting_deadlines.
Incident Log Format (JSONL)¶
Incidents are stored as an append-only JSONL file at ~/.opencastor/incidents.jsonl by default. Each line is a complete JSON incident entry.
# Append-only JSONL — one incident per line
{"id":"550e8400-e29b-41d4-a716-446655440000","timestamp":"2026-04-11T10:30:00.000Z","severity":"life_health","category":"motor_stall","description":"Left drive motor stalled under load during navigation","system_state":{"estop_active":false,"driver":"pca9685","duty":0.85}}
{"id":"6ba7b810-9dad-11d1-80b4-00c04fd430c8","timestamp":"2026-04-11T14:15:00.000Z","severity":"other","category":"provider_timeout","description":"AI provider response exceeded 5s timeout during REASONING task","system_state":{"provider":"anthropic","task_category":"REASONING","timeout_ms":5000}}
Entry Field Reference¶
| Field | Type | Required | Description |
|---|---|---|---|
id |
string | MUST | UUID v4 — unique identifier for deduplication. |
timestamp |
string | MUST | ISO-8601 UTC timestamp when the incident was recorded. |
severity |
string | MUST | "life_health" (15-day reporting deadline) or "other" (90-day deadline). |
category |
string | MUST | Short category tag (e.g. "motor_stall", "provider_timeout"). |
description |
string | MUST | Human-readable description of what happened. |
system_state |
object | SHOULD | Snapshot of relevant system state at the time of incident. |
Report Schema (rcan-incidents-v1)¶
{
"schema": "rcan-incidents-v1",
"generated_at": "2026-04-11T15:00:00.000Z",
"total_incidents": 2,
"incidents_by_severity": { "life_health": 1, "other": 1 },
"reporting_deadlines": {
"life_health": "15 days from incident timestamp",
"other": "90 days from incident timestamp"
},
"art72_note": "Providers must report serious incidents to the relevant national authority within the applicable deadline per EU AI Act Art. 72.",
"incidents": [...]
}