High-Risk AI Importer Due Diligence

What this control does

Verify supplier/provider conformity and maintain importer controls before and after EU market placement.

How to implement

For an importer of high-risk AI, establish a documented check before placing the system on the EU market. Verify the applicable assessment, technical documentation, marking, instructions and representative arrangements. Check importer identification and conditions during storage or transport. Hold systems with unresolved non-conformity or suspected falsified documentation, follow the required escalation route, and retain the records needed for cooperation and verification. Reassess the organization's role if its own actions may trigger Article 25.

Suggested timing and triggers

Before each relevant market placement; while responsible for storage or transport; on non-conformity, requests or role-changing modifications.

Evidence examples

Pre-market importer checklist and verified supplier documents Importer identification and logistics checks Hold, release and escalation decisions Required retained conformity records Authority responses and role-reassessment records

How to check this control

Select a market-placement decision and verify that the checks were completed beforehand against the actual system. Follow an exception through its resolution, and test retrieval of a required retained record.