Authorised representative
An authorised representative is an EU-established entity appointed by a non-EU provider of a high-risk AI system (Article 22) or GPAI model (Article 54) to keep documentation available and act as the contact point for authorities.
The appointment is by written mandate. For high-risk systems the representative verifies that the declaration of conformity and technical documentation have been drawn up and the conformity assessment carried out, keeps the documentation and provider contact details available to authorities for ten years, provides information and documentation on a reasoned request, and cooperates on any action taken. Critically, the representative must terminate the mandate and inform the authorities if it believes the provider is acting contrary to its obligations — it is a supervisory anchor, not a mailbox.
- Art. 22
- Art. 54
Authorised representative: why it matters
Without an appointed representative, an importer or distributor is prohibited from placing the non-EU provider's high-risk system on the EU market, which turns the appointment into a commercial precondition rather than a legal formality. It is also a live obligation for GPAI providers today under Article 54, whereas the high-risk equivalent bites with the Annex III regime — so third-country model providers need one now, not in 2027.
Authorised representative in practice
A Canadian company selling an AI-based industrial safety component to EU manufacturers appoints a Dublin consultancy by written mandate. The consultancy holds a copy of the Annex IV file and the declaration of conformity, answers the Irish market-surveillance authority directly in English or Irish, and — because the mandate lets it — would resign and notify the regulator if the Canadian provider refused to update the documentation after a design change.
Authorised representative: the mistake people make
Treating the representative as a registered-address service. The mandate carries real duties and real liability, the representative must actually hold the documentation, and it can be held responsible alongside the provider — which is why generic company-formation providers are a poor fit for the role.
Authorised representative: common questions
- Who needs an EU authorised representative?
- Providers established outside the Union that place a high-risk AI system on the EU market (Article 22) or a general-purpose AI model on the EU market (Article 54). The appointment must be made before the system or model is placed on the market.
- What does the authorised representative actually do?
- Verifies the conformity documentation exists, keeps it available to authorities for ten years, acts as contact point for national authorities and the AI Office, cooperates with any action taken, and terminates the mandate if the provider acts contrary to its obligations.
- Can our EU subsidiary be the authorised representative?
- Yes, provided it is established in the Union and holds a written mandate that gives it the powers Article 22 requires — including access to the documentation and the ability to end the mandate and notify authorities.
Authorised representative: terms that come up alongside it
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