§ EU AI Act · Article 23
AI Act Article 23: Obligations, Deadlines & Penalties
At a glance
Article 23 of the AI Act imposes 12 obligations on importer. At least one obligation carries an explicit compliance deadline.
§ Obligations
All obligations under Article 23
Obligation 1
Before placing a high-risk AI system on the market, importers must verify that the relevant conformity assessment procedure has been carried out by the provider.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
verify
- Deadline
-
before placing on the market
- Penalty
-
—
Obligation 2
Before placing a high-risk AI system on the market, importers must verify that the provider has drawn up the technical documentation in accordance with Article 11 and Annex IV.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
verify
- Deadline
-
before placing on the market
- Penalty
-
—
Obligation 3
Before placing a high-risk AI system on the market, importers must verify that the system bears the required CE marking and is accompanied by the EU declaration of conformity and instructions for use.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
verify
- Deadline
-
before placing on the market
- Penalty
-
—
Obligation 4
Before placing a high-risk AI system on the market, importers must verify that the provider has appointed an authorised representative in accordance with Article 22(1).
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
verify
- Deadline
-
before placing on the market
- Penalty
-
—
Obligation 5
Where an importer has sufficient reason to consider that a high-risk AI system is not in conformity with this Regulation, or is falsified, or accompanied by falsified documentation, it shall not place the system on the market until it has been brought into conformity.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
refrain from placing on market
- Deadline
-
until brought into conformity
- Penalty
-
—
Obligation 6
Where the high-risk AI system presents a risk, the importer shall inform the provider of the system, the authorised representative and the market surveillance authorities to that effect.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
inform
- Deadline
-
—
- Penalty
-
—
Obligation 7
Importers shall indicate their name, registered trade name or registered trade mark, and the address at which they can be contacted on the high-risk AI system and on its packaging or its accompanying documentation, where applicable.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
indicate
- Deadline
-
—
- Penalty
-
—
Obligation 8
Importers shall ensure that, while a high-risk AI system is under their responsibility, storage or transport conditions, where applicable, do not jeopardise its compliance with the requirements set out in Section 2.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
ensure
- Deadline
-
while under their responsibility
- Penalty
-
—
Obligation 9
Importers shall keep, for a period of 10 years after the high-risk AI system has been placed on the market or put into service, a copy of the certificate issued by the notified body, where applicable, of the instructions for use, and of the EU declaration of conformity.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
keep
- Deadline
-
10 years after placing on the market or putting into service
- Penalty
-
—
Obligation 10
Importers shall provide the relevant competent authorities, upon a reasoned request, with all the necessary information and documentation to demonstrate the conformity of a high-risk AI system with the requirements set out in Section 2 in a language which can be easily understood by them.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
provide
- Deadline
-
upon a reasoned request
- Penalty
-
—
Obligation 11
Importers shall ensure that the technical documentation can be made available to the relevant competent authorities upon a reasoned request.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
ensure availability
- Deadline
-
upon a reasoned request
- Penalty
-
—
Obligation 12
Importers shall cooperate with the relevant competent authorities in any action those authorities take in relation to a high-risk AI system placed on the market by the importers, in particular to reduce and mitigate the risks posed by it.
Regulation (EU) 2024/1689, Article 23, Article 23
- Obligated entity
-
importer
- Action required
-
cooperate
- Deadline
-
—
- Penalty
-
—
§ Deadlines
EU AI Act compliance deadlines
-
2025-02-02
Article 4 AI literacy
in_force
-
2025-02-02
Article 5 prohibitions (unacceptable risk)
in_force
-
2025-08-02
GPAI model obligations (Articles 51 to 56)
in_force
-
2026-08-02
Article 50(2) machine-readable marking (watermarking) of AI-generated content
provisionally_amended
-
2026-08-02
Article 50 transparency obligations OTHER than the 50(2) marking grace (for example disclosure that a user is interacting with an AI system)
scheduled
-
2026-08-02
Annex III stand-alone high-risk obligations
provisionally_amended
-
2026-08-02
National AI regulatory sandboxes (establishment deadline)
provisionally_amended
-
2026-12-02
NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM
provisionally_amended
-
2027-08-02
Annex I embedded (regulated-product) high-risk obligations
provisionally_amended
§ Frequently asked
Questions about Article 23
Who must comply with Article 23 of the AI Act?
+
importer.
What does Article 23 of the AI Act require?
+
verify refrain from placing on market inform
What is the compliance deadline for AI Act Article 23?
+
10 years after placing on the market or putting into service; before placing on the market; until brought into conformity; upon a reasoned request; while under their responsibility