§ EU AI Act · Article 91
AI Act Article 91: Obligations, Deadlines & Penalties
At a glance
Article 91 of the AI Act imposes 3 obligations on clients of lawyers, persons authorised to represent the provider, provider of general-purpose AI model. At least one obligation carries an explicit compliance deadline. Non-compliance may result in administrative fines or other penalties.
§ Obligations
All obligations under Article 91
Obligation 1
The provider of a general-purpose AI model, or its representative, must supply the documentation drawn up in accordance with Articles 53 and 55, or any additional information necessary for assessing compliance, within the period set by the Commission.
Regulation (EU) 2024/1689, Article 91, Article 91
- Obligated entity
-
provider of general-purpose AI model
- Sector scope
- general-purpose AI models
- Action required
-
provide
- Deadline
-
within the period set in the request
- Penalty
-
fines provided for in Article 101 for supplying incorrect, incomplete or misleading information
Obligation 2
In the case of legal persons, companies, or firms, the persons authorised to represent them by law or statutes must supply the requested information on behalf of the provider.
Regulation (EU) 2024/1689, Article 91, Article 91
- Obligated entity
-
persons authorised to represent the provider
- Sector scope
- general-purpose AI models
- Action required
-
provide
- Deadline
-
within the period set in the request
- Penalty
-
fines provided for in Article 101 for supplying incorrect, incomplete or misleading information
Obligation 3
Lawyers duly authorised to act may supply information on behalf of their clients, but the clients remain fully responsible if the information supplied is incomplete, incorrect, or misleading.
Regulation (EU) 2024/1689, Article 91, Article 91
- Obligated entity
-
clients of lawyers
- Sector scope
- general-purpose AI models
- Action required
-
ensure accuracy
- Deadline
-
—
- Penalty
-
fines provided for in Article 101 for supplying incorrect, incomplete or misleading information
§ 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 91
Who must comply with Article 91 of the AI Act?
+
clients of lawyers, persons authorised to represent the provider, provider of general-purpose AI model.
What does Article 91 of the AI Act require?
+
provide ensure accuracy
What is the compliance deadline for AI Act Article 91?
+
within the period set in the request
What are the penalties for non-compliance with AI Act Article 91?
+
fines provided for in Article 101 for supplying incorrect, incomplete or misleading information