High-Risk AI Distributor Due Diligence

Verify conformity indicators and maintain distributor controls before and after making high-risk AI available.

For a distributor of high-risk AI, check the applicable marking, accompanying information and provider/importer obligations before making the system available. Keep storage and transport conditions from undermining conformity. Withhold systems with unresolved issues, and coordinate required correction or market action for systems already distributed. Retain sufficient records to respond to competent authorities. Reassess whether rebranding or modification makes the organization a provider under Article 25 rather than only a distributor.

Before distribution; while responsible for storage or transport; on relevant issues, changes or regulator requests.

Distribution verification checklist and accompanying documents Storage and transport controls Withhold/release decisions and corrective-action records Supplier and authority correspondence Affected-customer or system records where relevant

Sample a distribution decision and compare the recorded checks with the system and documents supplied. Trace one issue to the hold or corrective action, and verify that the relevant parties were informed.