EU AI Act Authorised Representative — Articles 22 & 54
Providers of high-risk AI systems (Article 22(1)) and providers of general-purpose AI models (Article 54(1)) that are established in third countries must, by written mandate, appoint an authorised representative established in the Union before their systems or models reach the Union market — Regulation (EU) 2024/1689 (Artificial Intelligence Act). Regingada UG (haftungsbeschränkt) takes on that named role under its own written mandate: document custody and verification, authority cooperation and documentation — not legal advice.
AI Act authorised representative service — authorized representative in US spelling — for non-EU providers of high-risk AI systems and general-purpose AI (GPAI) models.
Software & appointed EU representation: Regingada UG (haftungsbeschränkt) · Legal advice exclusively: Kanzlei Theo Funk — separate mandate
Who must appoint an authorised representative under the AI Act
The AI Act creates the role twice, for two different circles of providers. Both circles are defined the same way: the provider is established in a third country, and its systems or models reach the Union market. Jump to the circle that concerns you:
- Article 22 — high-risk AI systems
- Article 54 — GPAI models
- When the duties apply
- Representative vs importer
Circle A — Article 22: providers of high-risk AI systems
Prior to making their high-risk AI systems available on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union (Article 22(1) AI Act). Whether a system is high-risk follows from the classification rules of Article 6: AI systems that are safety components of — or are themselves — products covered by the Union harmonisation legislation listed in Annex I (Article 6(1)), and the stand-alone use cases listed in Annex III (Article 6(2)), from biometrics to employment, credit and law enforcement.
Circle B — Article 54: providers of general-purpose AI models
Prior to placing a general-purpose AI model on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union (Article 54(1) AI Act). A general-purpose AI model is a model that displays significant generality and is capable of competently performing a wide range of distinct tasks, and that can be integrated into a variety of downstream systems or applications (Article 3(63) AI Act). Article 54(6) carves out certain free and open-source models — see the FAQ below.
Both groups use the same instrument: a written mandate with a representative established in the Union. Which of them you fall into — or whether you fall into both — is exactly what the scoping on this page records.
When the duties apply
- 2 Aug 2025
Article 54 already applies — the general-purpose AI chapter has applied since 2 August 2025. For GPAI models placed on the market before that date, providers have until 2 August 2027 to comply (Article 111(3) AI Act).
- 2 Aug 2026
Article 22 applies for high-risk AI systems — the general application date of the Regulation.
- 2 Aug 2027
For high-risk AI systems under Article 6(1) — products covered by Annex I — the obligations apply from 2 August 2027.
Authorised representative vs importer (Article 23)
The AI Act keeps the roles apart in Article 3: the authorised representative (Article 3(5)) acts on a written mandate from the provider and carries out the provider’s obligations on its behalf; the importer (Article 3(6)) is a person located or established in the Union that places an AI system bearing the name or trademark of a third-country person on the Union market, with its own obligations catalogue under Article 23. One role does not substitute the other — Article 22(1) ties the appointment duty to the provider’s establishment in a third country, not to whether an importer is involved.
What the authorised representative does
The representative performs the tasks specified in the written mandate — and the Regulation dictates what that mandate must cover. The mandate also empowers the representative to be addressed, in addition to or instead of the provider, by the competent authorities on all issues related to ensuring compliance, and a copy of it is provided to the market surveillance authority upon request.
For high-risk AI systems (Article 22(3))
- Verify that the EU declaration of conformity (Article 47) and the technical documentation (Article 11) have been drawn up and that the provider has carried out the appropriate conformity assessment procedure — Article 22(3)(a)
- Keep at the disposal of the competent authorities, for ten years after the system has been placed on the market or put into service: the provider’s contact details, a copy of the EU declaration of conformity, the technical documentation and, where applicable, the certificate issued by the notified body — Article 22(3)(b)
- Provide a competent authority, upon reasoned request, with the information and documentation necessary to demonstrate conformity — including access to the logs automatically generated by the system (Article 12(1)), to the extent they are under the provider’s control — Article 22(3)(c)
- Cooperate with competent authorities in any action they take in relation to the system, in particular to reduce and mitigate its risks — Article 22(3)(d)
- Where applicable, comply with the registration obligations of Article 49(1) — or, if the provider registers itself, ensure that the information referred to in Annex VIII, Section A, point 3 is correct — Article 22(3)(e)
For general-purpose AI models (Article 54(3))
- Verify that the technical documentation set out in Annex XI has been drawn up and that all obligations under Article 53 — and, where applicable, Article 55 — have been fulfilled by the provider — Article 54(3)(a)
- Keep a copy of the technical documentation at the disposal of the AI Office and the national competent authorities for ten years after the model has been placed on the market, together with the provider’s contact details — Article 54(3)(b)
- Provide the AI Office, upon reasoned request, with the information and documentation necessary to demonstrate compliance — Article 54(3)(c)
- Cooperate with the AI Office and competent authorities in any action they take in relation to the model, including when it is integrated into AI systems placed on the market or put into service in the Union — Article 54(3)(d)
The mandate also has a required exit path: under Article 22(4) — mirrored for models in Article 54(5) — the authorised representative must terminate the mandate if it considers or has reason to consider that the provider is acting contrary to its obligations under the Regulation, and must immediately inform the relevant market surveillance authority and, where applicable, the relevant notified body — for models, the AI Office — giving reasons. Our representation contract defines the information flows so that duty never has to be triggered by surprise.
How the appointment works
Three steps take you from scoping to a written mandate and documented representative function.
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Scoping
A guided question set — the same wizard you can start on this page — records your provider role, your establishment, and whether your portfolio falls under Article 22 (high-risk systems), Article 54 (GPAI models) or both.
Deliverablea structured self-assessment record of your Article 22 / Article 54 status — not a legal determination; for that, the law firm advises under a separate mandate.
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Written mandate
We prepare the written mandate the Regulation requires: the task catalogue of Article 22(3) or Article 54(3), document flows, escalation paths and response times — the mandate copy authorities may request.
Deliverablea draft written mandate and representation contract covering the statutory task catalogue — model terms on request.
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Documentation & registration setup
We set up the ten-year document custody — EU declaration of conformity, technical documentation under Article 11 or Annex XI — plus the Article 49 registration step where applicable.
Deliverablea documented custody and retrieval plan, the registration record where applicable, and a documented contact channel for market surveillance authorities and the AI Office.
A named role, held by a registered company.
“Under the AI Act the representative role is document-heavy: declarations of conformity, technical documentation, registrations — someone established in the Union must verify, hold and produce them on request, for ten years. Regingada holds that named role under its own written mandate. Legal judgment stays with my firm, under a separate mandate.”
Regingada UG (haftungsbeschränkt), HRB 12595, AG Bamberg
Appointed EU representative & software: Regingada UG (haftungsbeschränkt) — wholly owned by German attorney Theo Funk, no legal advice · Legal advice: independent law firm Kanzlei Theo Funk (RAK Bamberg) — separate mandate.
EU data discipline → Trust Center · security.txt (RFC 9116)
The same regulatory corpus powers the Regingada Compliance Suite — digital-twin software that maps the AI Act alongside the GDPR, the DSA, the DMA and NIS2.
From the Regingada Radar — we track what we represent
What determines the cost
The engagement is priced by what the role actually has to carry: the number and classification of your AI systems and models (high-risk under Article 6, GPAI under Chapter V), the volume of technical documentation to keep and verify, registration duties under Article 49, the expected volume of authority contacts — market surveillance authorities and, for models, the AI Office — whether the role is combined with Article 27 GDPR, DSA or NIS2 representation (multi-regime setups reduce coordination overhead), and the response times we commit to.
Engagement terms on request.
Frequently asked questions
Who must appoint an authorised representative under the AI Act?
Two circles of providers, both defined by establishment outside the Union: providers of high-risk AI systems established in third countries must appoint an authorised representative prior to making their systems available on the Union market (Article 22(1) AI Act); providers of general-purpose AI models established in third countries must do so prior to placing the model on the Union market (Article 54(1) AI Act). In both cases the appointment is made by written mandate, and the representative must be established in the Union.
Article 22 vs Article 54 — which one applies to me?
Article 22 attaches to high-risk AI systems — systems classified under Article 6, either as safety components of products covered by the Union harmonisation legislation listed in Annex I (Article 6(1)) or through the use cases listed in Annex III (Article 6(2)). Article 54 attaches to general-purpose AI models as defined in Article 3(63). A provider that places both a GPAI model and high-risk AI systems on the Union market falls under both circles; both mandates can sit with the same representative.
From when do the representative duties apply?
Article 54 already applies: the general-purpose AI chapter has applied since 2 August 2025 — for GPAI models placed on the market before that date, providers have until 2 August 2027 to comply (Article 111(3) AI Act). Article 22 applies from 2 August 2026. For high-risk AI systems under Article 6(1) — products covered by Annex I — the obligations apply from 2 August 2027.
What does the authorised representative actually do?
The tasks come from the written mandate, which must cover the statutory catalogue: verifying that the EU declaration of conformity and the technical documentation have been drawn up (Article 22(3)(a)) or that the Annex XI documentation and the Article 53 obligations are fulfilled (Article 54(3)(a)); keeping documentation at the disposal of the authorities for ten years; providing information and documentation upon reasoned request; cooperating with the competent authorities and, for models, the AI Office; and, where applicable, the registration steps under Article 49. The mandate also empowers the representative to be addressed by the authorities, in addition to or instead of the provider, on all issues related to ensuring compliance.
Authorised representative vs importer vs distributor — what is the difference?
The AI Act keeps the roles apart in Article 3: the authorised representative (Article 3(5)) is located or established in the Union and acts on a written mandate from the provider, carrying out the provider's obligations on its behalf. The importer (Article 3(6)) places an AI system bearing the name or trademark of a person established in a third country on the Union market and has its own obligations under Article 23. The distributor (Article 3(7)) makes a system available further down the supply chain, with the obligations of Article 24. One role does not substitute another: Article 22(1) ties the appointment duty to the provider's establishment in a third country, not to whether an importer is involved.
What happens if a non-EU provider does not appoint one?
The Regulation words the appointment as a precondition: it must happen before high-risk AI systems are made available on the Union market (Article 22(1) AI Act) and before a general-purpose AI model is placed on the Union market (Article 54(1) AI Act). Without the appointment that condition is not met, and the market surveillance framework of Chapter IX AI Act applies to the non-compliance. What this means for a specific market-entry plan is a legal question — the law firm advises on it under a separate mandate.
Is there an exemption for open-source GPAI models?
Article 54(6) contains one: the authorised-representative obligation does not apply to providers of general-purpose AI models released under a free and open-source licence that allows access, usage, modification and distribution of the model, and whose parameters — including the weights, the information on the model architecture and the information on model usage — are made publicly available. The exemption does not apply where the model presents a systemic risk.
Is this legal advice?
Regingada UG (haftungsbeschränkt) is the software and EU-representation company, wholly owned by attorney Theo Funk. It does not provide legal advice. For legal advice under a separate mandate, please see the independent law firm Kanzlei Theo Funk.
What does it cost?
The engagement depends on the number and classification of your AI systems and models, the volume of technical documentation to keep and verify, registration duties under Article 49, the expected volume of authority contacts, whether the role is combined with Article 27 GDPR, DSA or NIS2 representation (multi-regime setups reduce coordination overhead), and agreed response times. Engagement terms on request.
Appoint your AI Act authorised representative.
Start with the scoping check — it records your Article 22 / Article 54 status and leads straight into the representation request. Article 54 already applies.
Legal advice on representative obligations — Kanzlei Theo Funk (separate mandate)