Authorized Representatives Under the EU AI Act

Article 22 requires a provider of a high-risk AI system established in a third country to appoint, by written mandate, an authorized representative established in the Union before placing the system on the EU market. The representative verifies that the required EU declaration of conformity and technical documentation have been drawn up, keeps specified documents and contact information available to competent authorities, and provides information and cooperation when authorities make a reasoned request. The mandate must enable the representative to perform the listed tasks. The representative’s role is operational and regulatory, not a transfer of all provider duties. The provider remains responsible for designing the system, meeting applicable requirements, conducting conformity assessment, preparing documentation, and taking corrective action. A representative should not sign a mandate that gives it no access to the materials needed to answer authority requests. The provider must also supply necessary information, documentation, and means of cooperation. The Act contains a separate authorized-representative regime for certain providers of general-purpose AI models established outside the Union under Article 54. Do not assume that a representative appointed for a GPAI model automatically covers a separate high-risk system, or vice versa. Identify the regulated object and article, the provider’s establishment, and the obligations in scope. Other roles—importer, distributor, product manufacturer, or deployer—may also apply to entities in the chain. A written mandate should specify the exact system or model, document access, authority-contact process, retention period, escalation duties, and handling of corrective actions. Confirm that the representative is established in the EU and can perform the work. Reassess when provider identity, system scope, or the legal text changes. The appointment is a compliance mechanism, not a certificate that the system conforms.