Authorized Representative Under the EU AI Act: Requirements for Non-EU Providers
Who this applies to
This obligation applies to providers of high-risk AI systems (Article 24(1)) and general-purpose AI models (Article 25(1)) that are established outside the EU but place their systems on the EU market. It also covers importers and distributors acting as authorized representatives under Article 24(2).What is required
- Appointment of an EU-based authorized representative (Article 24(1)): Non-EU providers must designate a natural or legal person established in the EU to act on their behalf for compliance and enforcement matters.
- Written mandate (Article 24(3)): The authorized representative must hold a written mandate empowering them to:
- Registration in the EU database (Article 51(1)): The authorized representative’s details must be recorded in the EU AI database before market placement.
- Liability for non-compliance (Article 24(5)): The authorized representative is jointly liable for defective administrative compliance, though not for product defects under civil liability rules.
Key deadlines
Under Article 113 as written, the primary deadline for this obligation is August 2, 2026. The Digital Omnibus provisional agreement of 7 May 2026 moves Annex III high-risk obligations to 2 December 2027, pending formal adoption; until Official Journal publication, the original date remains law.Enforcement patterns
AI Act Article 50 transparency obligations take effect 2 August 2026. Annex III high-risk obligations are expected 2 December 2027, pending formal adoption of the Digital Omnibus (political agreement of 7 May 2026). No AI Act enforcement precedent currently exists. This page will be updated as enforcement cases emerge.Cross-border considerations
Implementation varies by member state, with Italy (IT), Belgium (BE), and Austria (AT) showing the highest citation density for Articles 24–25 in national guidance. No jurisdiction-specific deviations from the AI Act’s authorized representative requirements have been documented in enforcement or cross-reference data.Fontvera also analyses closely related obligations, including [AI Act Article 17 on provider obligations](/intelligence/ai-act-art-17-provider-obligations), [AI Act deepfakes FAQ](/intelligence/ai-act-faq-deepfakes), [AI Act social scoring FAQ](/intelligence/ai-act-faq-social-scoring), and [AI Act penalties by violation type](/intelligence/ai-act-penalties-by-violation-type).