An Authorised Representative (AR) is the official legal representative in the European Union for providers of AI systems or models established outside the EU. Their role is clearly defined in the EU Artificial Intelligence Act and is essential for ensuring that non-EU providers can comply with the regulation and that European authorities can effectively exercise oversight.
The duties of the Authorised Representative are primarily set out in two articles of the EU AI Act:
These articles establish both the mandatory appointment of an AR and the specific tasks they are required to perform.
The Authorised Representative must carry out the following key responsibilities:
The AR serves as the primary interface between the non-EU provider and European regulators, including:
They receive official communications, requests for information, and notifications on behalf of the provider and are responsible for responding in a timely and accurate manner.
One of the most important duties is to keep copies of all required documentation and make them available to authorities upon request. This includes:
These records must generally be retained for at least 10 years after the AI system or model has been placed on the market.
The AR is responsible for verifying that the provider has fulfilled its legal obligations under the AI Act. This includes:
The AR must cooperate fully with any investigations or audits conducted by EU authorities. This can involve:
The AR assists the provider in fulfilling ongoing obligations, such as:
The exact scope of the AR's duties is defined in the written mandate signed between the provider and the AR. This mandate must explicitly authorise the representative to carry out all necessary tasks and to be addressed directly by authorities.
The AR is not merely a passive contact point. They also have important rights and obligations:
While the core duties are broadly similar, there are some differences in emphasis:
| Duty | High-Risk AI Systems (Art. 22) | GPAI Models (Art. 54) |
|---|---|---|
| Technical Documentation | Must cover all Annex IV requirements | Must cover Annex XI requirements |
| Focus of Verification | Risk management, data quality, human oversight | Model capabilities, systemic risk assessment |
| Interaction with Authorities | National authorities + notified bodies | Primarily the European AI Office |
| Post-Market Obligations | Strong emphasis on monitoring and incidents | Focus on model updates and systemic risks |
For companies appointing an Authorised Representative, it is important to understand that:
The Authorised Representative under the EU AI Act carries significant responsibilities that go far beyond being a mere mailbox or contact point. Their duties include regulatory liaison, documentation management, compliance verification, incident support, and cooperation with authorities - all underpinned by a formal written mandate.
By performing these tasks effectively, the AR helps bridge the gap between non-EU providers and the European regulatory system, ensuring that the objectives of the AI Act - protecting health, safety, and fundamental rights - can be achieved in practice.
For any non-EU company developing or supplying high-risk AI systems or general-purpose AI models, selecting a competent and reliable Authorised Representative is one of the most important compliance decisions they will make.