Artificial Intelligence Policy Tracker
Legal requirement Governance and accountability European Union Partially applicable

Non-EU providers of GPAI models must appoint an EU authorised representative

Download: JSON · MarkdownUnder EU AI Act, Article 54

Verified against the official source 26 Sep 2026 (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

Non-EU providers of GPAI models must appoint an EU authorised representative is a legal requirement under the EU AI Act in the European Union (Article 54). Before placing a general-purpose AI model on the Union market, a provider established in a third country must appoint, by written mandate, an authorised representative established in the Union.

Instrument
EU AI Act
Jurisdiction
European Union
Nature
Legal requirement
Source reference
Article 54
Applies from
2 August 2025
Who it binds
Authorised representative, General-purpose AI model provider
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 placing a general-purpose AI model on the Union market, a provider established in a third country must appoint, by written mandate, an authorised representative established in the Union. The representative checks that the Annex XI documentation exists and the Article 53 duties are met, keeps a copy of the documentation and the provider's contact details for ten years after market placement, provides information to the AI Office on request, cooperates with authorities, and must end the mandate if the provider breaches the Regulation. Open-source models without systemic risk are exempt.

Practical action

Appoint an EU representative under a written mandate covering document retention and AI Office liaison before the model reaches EU users.

Who does it apply to?

Providers of general-purpose AI models established outside the EU, unless the model is free and open-source and not of systemic risk.

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 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

    The mandate and its task list.

  • supportsProcessProduct or model owner · at launch and on material change
    Technical documentation, model cards and instructions for use

    Serves 14 recorded duties · evidence: Technical documentation file, Model card or deployer information pack, Instructions for use

    The documentation the representative holds.

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 12 templates that cover it →

What evidence would a reviewer expect?

Evidence examples
EvidenceTypeNotes
Written mandate of authorised representative for GPAIdocument
Representative's verification of Annex XI documentationrecord

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 42001:2023Clause 5.3; Annex A.10.2Responsibilities allocated to an external party.medium
NIST AI RMF 1.0GOVERN 2.1, GOVERN 6.1Roles and third-party arrangements.low

Frequently asked questions

Is this a legal requirement?

Yes. It is a legal requirement under EU AI Act (Article 54).

Who must comply with this obligation?

Providers of general-purpose AI models established outside the EU, unless the model is free and open-source and not of systemic risk.

When does this obligation apply?

It applies from 2 August 2025.

What evidence shows compliance?

A reviewer would expect: Written mandate of authorised representative for GPAI; Representative's verification of Annex XI documentation.

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; Technical documentation, model cards and instructions for use.

What should an organisation do in practice?

Appoint an EU representative under a written mandate covering document retention and AI Office liaison before the model reaches EU users.

Cite this record

AIPolicyTracker (2026). “Non-EU providers of GPAI models must appoint an EU authorised representative (EU AI Act)” [AIPT-OBL-0044, verified 26 September 2026]. https://aipolicytracker.org/id/AIPT-OBL-0044 (accessed 8 November 2026). Data licensed CC BY 4.0.

Permanent id AIPT-OBL-0044: 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_noneuprovidersofgpaimode,
  author       = {{AIPolicyTracker}},
  title        = {{Non-EU providers of GPAI models must appoint an EU authorised representative (EU AI Act)}},
  year         = {2026},
  howpublished = {\url{https://aipolicytracker.org/obligations/eu-ai-act-art-54-gpai-authorised-representative}},
  url          = {https://aipolicytracker.org/obligations/eu-ai-act-art-54-gpai-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

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