Verify conformity before importing or distributing high-risk AI
Download: JSON · MarkdownUnder EU AI Act, Articles 23 and 24
What this label means
- Verified
- — a named reviewer opened the official source and confirmed the record; the date and the reviewer are shown.
- Pending review
- — linked to the official source and in the queue for a reviewer to confirm.
- Source-linked
- — linked to the official source, not yet confirmed by a reviewer.
On this page 9 sections
In brief
Verify conformity before importing or distributing high-risk AI is a legal requirement under the EU AI Act in the European Union (Articles 23 and 24). Importers must verify that the provider completed conformity assessment, drew up technical documentation, affixed CE marking and appointed an authorised representative where required, and must indicate their name and contact details on the system.
- Instrument
- EU AI Act
- Jurisdiction
- European Union
- Nature
- Legal requirement
- Source reference
- Articles 23 and 24
- Applies from
- 2 December 2027
- Who it binds
- Importer, Distributor
- Evidence examples
- 1
- Framework mappings
- ISO/IEC 42001:2023, NIST AI Risk Management Framework 1.0
- Controls that meet it
- 3
- Official source
- Open official text
- Verification
- Pending review · source-linked
What does it require?
Importers must verify that the provider completed conformity assessment, drew up technical documentation, affixed CE marking and appointed an authorised representative where required, and must indicate their name and contact details on the system. Distributors must verify CE marking, the declaration of conformity and instructions, and refrain from making non-compliant systems available.
Practical action
Build AI Act checks into supplier onboarding and contract clauses.
Who does it apply to?
Importers and distributors of high-risk AI systems.
- Actors
- ImporterDistributor
- Sectors
- Cross-sector / all sectors
- Use cases
- Safety-critical and infrastructure
Applies from:
Which controls meet this duty?
Satisfies: the control, operated properly, does the work the duty asks for. Supports: it contributes but the duty needs more. Each control page lists every other duty it serves, so work done once can be counted once.
-
satisfiesProcessProcurement or vendor risk lead · once per ai systemVendor and third-party AI due diligence
Serves 6 recorded duties · evidence: AI supplier due-diligence assessment, AI supplier and component register, Supplier onboarding decision
Onboarding verifies the provider's conformity assessment, documentation, marking and representative.
-
supportsProcessRegulatory compliance lead · once per ai systemConformity assessment, declaration and registration
Serves 4 recorded duties · evidence: Declaration of conformity or certificate, Registration record in the relevant database, Conformity evidence pack
Knowledge of the assessment route needed to verify it.
-
supportsContractual termLegal counsel · once per ai systemContractual allocation of AI duties across the supply chain
Serves 9 recorded duties · evidence: AI supplier clause set, AI customer or deployer clause set, Contract clause index against the AI register
Supplier terms require the paperwork and notice of changes.
Templates that cover this duty
Generated from the records. Free · no account · links emailed to your work address. This duty is cited in each file with its source reference and a link back here.
- EU AI Act Role and Risk Classifier
Checklist · XLSX · v4
- AI Vendor Due-Diligence Questionnaire
Checklist · XLSX and DOCX · v3
- EU AI Act Article 50 Transparency Kit
Kit · DOCX and XLSX · v44
- ISO/IEC 42001 Gap Assessment and Statement of Applicability
Assessment · XLSX · v3
What evidence would a reviewer expect?
| Evidence | Type | Notes |
|---|---|---|
| Supplier due-diligence checklist | record |
Framework mappings
Original editorial crosswalks. They cite clause numbers only and reproduce no standard text; confidence reflects how direct the mapping is.
See every European Union duty mapped this way →
| Framework | Reference | Note | Confidence |
|---|---|---|---|
| ISO/IEC 42001:2023 | Annex A controls on third parties and suppliers | Original editorial mapping. | medium |
| NIST AI RMF 1.0 | GOVERN 6.1, GOVERN 6.2 | Third-party risk management. | high |
Frequently asked questions
Is this a legal requirement?
Yes. It is a legal requirement under EU AI Act (Articles 23 and 24).
Who must comply with this obligation?
Importers and distributors of high-risk AI systems.
When does this obligation apply?
It applies from 2 December 2027.
What evidence shows compliance?
A reviewer would expect: Supplier due-diligence checklist.
Which frameworks map to this obligation?
It is mapped to ISO/IEC 42001:2023 Annex A controls on third parties and suppliers, NIST AI Risk Management Framework 1.0 GOVERN 6.1, GOVERN 6.2. These are editorial crosswalks with a stated confidence, not official mappings.
Which controls satisfy this obligation?
Conformity assessment, declaration and registration; Contractual allocation of AI duties across the supply chain; Vendor and third-party AI due diligence.
What should an organisation do in practice?
Build AI Act checks into supplier onboarding and contract clauses.
Cite this record
AIPolicyTracker (2026). “Verify conformity before importing or distributing high-risk AI (EU AI Act)” [AIPT-OBL-0022, not yet verified]. https://aipolicytracker.org/id/AIPT-OBL-0022 (accessed 8 November 2026). Data licensed CC BY 4.0.
Permanent id AIPT-OBL-0022: it never changes or gets reused, and its address keeps working if this page moves.
Cite the official text alongside it: Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence, Official Journal of the European Union, https://eur-lex.europa.eu/eli/reg/2024/1689/oj.
BibTeX
@misc{aipolicytracker2026_verifyconformitybeforeim,
author = {{AIPolicyTracker}},
title = {{Verify conformity before importing or distributing high-risk AI (EU AI Act)}},
year = {2026},
howpublished = {\url{https://aipolicytracker.org/obligations/eu-ai-act-importer-distributor-obligations}},
url = {https://aipolicytracker.org/obligations/eu-ai-act-importer-distributor-obligations},
urldate = {2026-11-08},
note = {Data licensed CC BY 4.0. Accessed 8 November 2026}
}
Change history
No change to this record's tracked fields has been recorded since 15 October 2026, when field-level history began.
Similar obligations in other instruments
- Providers of high-risk AI must have written agreements with suppliers of components, tools and services — EU AI Act, European Union
- Provide contestability, supply-chain transparency and records (guardrails 7 to 9) — Australian Voluntary AI Safety Standard, Australia (voluntary)
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.