EU AI Act · Arts. 22, 54

Appoint an authorised representative in the EU

As a provider established outside the EU, appoint an authorised representative established in the EU by written mandate before making a high-risk system (Art. 22) or a general-purpose AI model (Art. 54) available in the EU. The mandate must let the representative keep documentation available to authorities and cooperate with them. Providers of free and open-source models without systemic risk are exempt from the Art. 54 duty (Art. 54(6)).

By the Shieldra Compliance Team · Last updated 2026-09-16

What do you actually have to do?

As a provider established outside the EU, appoint an authorised representative established in the EU by written mandate before making a high-risk system (Art. 22) or a general-purpose AI model (Art. 54) available in the EU. The mandate must let the representative keep documentation available to authorities and cooperate with them. Providers of free and open-source models without systemic risk are exempt from the Art. 54 duty (Art. 54(6)).

Statutory basis: Arts. 22, 54 — https://artificialintelligenceact.eu/article/22/

Who does this apply to?

  • Provider

When does it apply?

  • 2025-08-02 — since 2 August 2025 for general-purpose AI model providers (Art. 54)
  • 2027-08-02 — 2 August 2027 for models placed on the market before 2 August 2025 (Art. 111(3))
  • 2028-08-02 — 2 August 2028 (Annex I, deferred by the Digital Omnibus)
  • 2027-12-02 — 2 December 2027 (Annex III, deferred by the Digital Omnibus)

Disclaimer

Compliance guidance, not legal advice. Confirm obligations with counsel. Pack verified 2026-09-16.

Frequently asked questions

What does "Appoint an authorised representative in the EU" require?

As a provider established outside the EU, appoint an authorised representative established in the EU by written mandate before making a high-risk system (Art. 22) or a general-purpose AI model (Art. 54) available in the EU. The mandate must let the representative keep documentation available to authorities and cooperate with them. Providers of free and open-source models without systemic risk are exempt from the Art. 54 duty (Art. 54(6)).

When does this obligation apply?

since 2 August 2025 for general-purpose AI model providers (Art. 54). 2 August 2027 for models placed on the market before 2 August 2025 (Art. 111(3)). 2 August 2028 (Annex I, deferred by the Digital Omnibus). 2 December 2027 (Annex III, deferred by the Digital Omnibus)

Who does this obligation apply to?

The provider role under the EU AI Act. Statutory basis: Arts. 22, 54.