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:
- Cooperate with national competent authorities (Article 24(4)(a))
- Ensure compliance documentation is available upon request (Article 24(4)(b))
- Facilitate corrective actions, including withdrawal or recall (Article 24(4)(c))
- 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
The primary deadline for this obligation is
August 2, 2026, when the AI Act’s market access provisions enter into force.
Enforcement patterns
AI Act enforcement begins August 2, 2026. No 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.