Non-EU providers must appoint an EU authorised representative for high-risk AI
Download: JSON · MarkdownUnder EU AI Act, Article 22
What this label means
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- Source-linked
- — linked to the official source, not yet confirmed by a reviewer.
On this page 9 sections
In brief
Non-EU providers must appoint an EU authorised representative for high-risk AI is a legal requirement under the EU AI Act in the European Union (Article 22). Before making a high-risk AI system available in the Union, a provider established outside the EU must appoint, by written mandate, an authorised representative established in the Union. It applies from 2 December 2027.
- Instrument
- EU AI Act
- Jurisdiction
- European Union
- Nature
- Legal requirement
- Source reference
- Article 22
- Applies from
- 2 December 2027
- Who it binds
- Provider / developer, Authorised representative
- Evidence examples
- 2
- Framework mappings
- ISO/IEC 42001:2023, NIST AI Risk Management Framework 1.0
- Controls that meet it
- 2
- Official source
- Open official text
- Verification
- Verified against the official source 26 Sep 2026
What does it require?
Before making a high-risk AI system available in the Union, a provider established outside the EU must appoint, by written mandate, an authorised representative established in the Union. The representative verifies that the EU declaration of conformity and technical documentation exist and that conformity assessment was done, keeps the provider's contact details and the documentation available for ten years, supplies information to authorities, cooperates with them, and must end the mandate if the provider acts contrary to the Regulation.
Practical action
Sign a written mandate with an EU-established representative and give them a controlled copy of the technical file and declaration.
Who does it apply to?
Providers established in a third country that place high-risk AI systems on the EU market; the mandated representative carries the listed tasks.
- Sectors
- Cross-sector / all sectors
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.
-
satisfiesContractual 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
The written mandate allocates the representative's tasks.
-
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
Items the representative must verify.
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.
- AI System Inventory
Register · XLSX and DOCX · v6
- EU AI Act Role and Risk Classifier
Checklist · XLSX · v4
- AI Acceptable Use Policy
Policy · DOCX · v1
- AI Governance Policy and RACI
Policy · DOCX and XLSX · v5
What evidence would a reviewer expect?
| Evidence | Type | Notes |
|---|---|---|
| Written mandate of authorised representative | document | |
| Representative's documentation checklist | record | Verification that the declaration, technical file and conformity assessment are in place. |
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 | Clause 5.3; Annex A.10.2 | Allocation of responsibilities to an external party. | medium |
| NIST AI RMF 1.0 | GOVERN 2.1, GOVERN 6.1 | Roles and third-party arrangements. | low |
Frequently asked questions
Is this a legal requirement?
Yes. It is a legal requirement under EU AI Act (Article 22).
Who must comply with this obligation?
Providers established in a third country that place high-risk AI systems on the EU market; the mandated representative carries the listed tasks.
When does this obligation apply?
It applies from 2 December 2027.
What evidence shows compliance?
A reviewer would expect: Written mandate of authorised representative; Representative's documentation checklist.
Which frameworks map to this obligation?
It is mapped to ISO/IEC 42001:2023 Clause 5.3; Annex A.10.2, NIST AI Risk Management Framework 1.0 GOVERN 2.1, GOVERN 6.1. These are editorial crosswalks with a stated confidence, not official mappings.
Which controls satisfy this obligation?
Contractual allocation of AI duties across the supply chain; Conformity assessment, declaration and registration.
What should an organisation do in practice?
Sign a written mandate with an EU-established representative and give them a controlled copy of the technical file and declaration.
Cite this record
AIPolicyTracker (2026). “Non-EU providers must appoint an EU authorised representative for high-risk AI (EU AI Act)” [AIPT-OBL-0028, verified 26 September 2026]. https://aipolicytracker.org/id/AIPT-OBL-0028 (accessed 8 November 2026). Data licensed CC BY 4.0.
Permanent id AIPT-OBL-0028: 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_noneuprovidersmustappoin,
author = {{AIPolicyTracker}},
title = {{Non-EU providers must appoint an EU authorised representative for high-risk AI (EU AI Act)}},
year = {2026},
howpublished = {\url{https://aipolicytracker.org/obligations/eu-ai-act-art-22-authorised-representative}},
url = {https://aipolicytracker.org/obligations/eu-ai-act-art-22-authorised-representative},
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
- Use high-risk AI as instructed, monitor it and inform affected people — EU AI Act, European Union
- Providers must meet the full set of provider duties for high-risk AI — EU AI Act, European Union
- Providers must supply conformity evidence and log access to authorities on request — EU AI Act, European Union
- Deployers, distributors and importers must assume provider duties when they rebrand or substantially modify high-risk AI — EU AI Act, European Union
- Law-enforcement deployers must obtain authorisation for post-remote biometric identification and report annually — EU AI Act, European Union
- Providers of GPAI models must notify the Commission within two weeks of meeting the systemic-risk threshold — EU AI Act, European Union
- Non-EU providers of GPAI models must appoint an EU authorised representative — EU AI Act, European Union
- Frontier developers must protect employees who report catastrophic-risk concerns — California SB 53, California (United States)
Disclaimer: informational only, not legal advice. Verify every claim against the linked official sources and consult a qualified lawyer before acting.