Appoint an EU Authorised Representative for High-Risk AI When the Provider Is Established Outside the Union

Applies to Provider established outside the EU; High-Risk AI.

Actors: Provider
AI class: High-Risk AI
Themes: Third Parties & Supply Chain

Tracker Networks Guidance

Before making a high-risk AI system available on the Union market, a provider established in a third country should appoint an authorised representative established in the EU through a written mandate and enable that representative to perform the required tasks. For Article 6(1)/Annex I systems, check Article 2(13) for any permitted limitation based on equivalent or higher sectoral requirements.

Official text

Article 22(1)-(2)Official source

1. 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. 2. The provider shall enable its authorised representative to perform the tasks specified in the mandate received from the provider.

Timing depends on the system

2 Dec 2027 — Article 6(2) / Annex III high-risk AI
2 Aug 2028 — Article 6(1) / Annex I Section A high-risk AI
2 Dec 2027 — Pre-existing Annex III high-risk AI type/model first placed on the market or put into service before 2027-12-02
2 Aug 2028 — Pre-existing Article 6(1) / Annex I high-risk AI type/model first placed on the market or put into service before 2028-08-02
2 Aug 2030 — Pre-existing high-risk AI intended to be used by public authorities

Suggested controls

Authorised Representative Governance
Appoint, mandate, monitor and support authorised representatives where required.

Related risks

AI Value Chain Compliance Failure
Suppliers, importers, distributors or authorised representatives may not provide the information, controls or cooperation needed for high-risk AI compliance.

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