Artificial Intelligence Policy Tracker
Legal requirement Vendor and supply-chain governance European Union Partially applicable

Verify conformity before importing or distributing high-risk AI

Download: JSON · MarkdownUnder EU AI Act, Articles 23 and 24

Pending review · linked to the official source, waiting for a reviewer to confirm it (a factual check against the official source, not a legal review or legal advice)
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.
Verification policy and current standing · a factual check, not legal advice.
No change recorded as of 26 Sep 2026 · official source last checked
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.

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 system
    Vendor 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 system
    Conformity 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 system
    Contractual 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.

All 8 templates that cover it →

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Supplier due-diligence checklistrecord

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 mappings table
FrameworkReferenceNoteConfidence
ISO/IEC 42001:2023Annex A controls on third parties and suppliersOriginal editorial mapping.medium
NIST AI RMF 1.0GOVERN 6.1, GOVERN 6.2Third-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

Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.