--- title: "AI Act Authorised Representative | GPAI Article 54" url: "https://www.engagecompliance.co/ai-act-representative" type: "service" date: "2026-08-27" --- # Authorised representative for GPAI providers Companies outside the EU that place a general-purpose AI model on the Union market must appoint an authorised representative in the Union under EU AI Act Article 54. The obligation is live now, and Engage Compliance acts as that representative directly from its EU establishment. **The short answer: if you are established outside the EU and you place a general-purpose AI model on the Union market, Article 54 requires you to appoint, by written mandate and before the model goes on the market, an authorised representative established in the Union.** Engage Compliance provides that role from its EU establishment, holds the mandate and the Annex XI technical documentation for the AI Office, and is the contact point for the provider. This is the part of the AI Act that bites first. The general-purpose AI rules in Chapter V have applied since 2 August 2025, so unlike the high-risk representative duty, which comes later, this one is already in force. ## Key takeaways - Article 54 requires a provider established in a third country to appoint an authorised representative in the Union, by written mandate, before placing a general-purpose AI model on the Union market. - Engage Compliance acts as that authorised representative directly from its EU establishment. Article 3(5) requires only that the representative be located or established in the Union, with no single Member State specified, so no separate local entity is needed. - The obligation is live. Chapter V applies from 2 August 2025. - The exemption for free and open-source models is real but narrow, and it falls away entirely if the model presents systemic risks. - Most SaaS companies are not caught. If your product runs on a third-party model, you are a deployer or a downstream provider, not the provider of the model. - Pricing is scoped to the mandate. Talk to us for a quote. ## Who needs a GPAI authorised representative Article 54(1) is direct: prior to placing a general-purpose AI model on the Union market, providers established in third countries must, by written mandate, appoint an authorised representative established in the Union. Two elements decide it. You have to be the provider of a general-purpose AI model, meaning the entity that develops and places the model itself on the market, and you have to be established outside the EU. If both hold and the model reaches the Union market, the appointment is required before it does. The point most companies get wrong is the first element. Building a feature on top of OpenAI, Anthropic, Google, or any other provider's model does not make you a GPAI provider. It makes you a deployer, or at most a downstream provider of an AI system built on someone else's model. The Article 54 duty sits with whoever provides the underlying general-purpose model, not with the many companies that use one. If that is not you, this is not your obligation, and we will tell you so at the scoping stage rather than sell you a mandate you do not need. ## Who is exempt Article 54(6) exempts providers of general-purpose AI models released under a free and open-source license that allows access, use, modification, and distribution of the model, where the parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available. There is one condition that swallows the exemption in the cases that matter most. It does not apply where the model presents systemic risks. A model at that tier loses the open-source carve-out and attracts the additional obligations that go with systemic risk, which the representative has to be able to show were addressed. So an open-weight release is only exempt while it stays below the systemic-risk line. ## When it applies from Chapter V of the AI Act, which contains Article 54, applies from 2 August 2025. The obligation to appoint the representative before a general-purpose AI model is placed on the Union market is in force today. This is the reason to start with Article 54 rather than the high-risk representative duty under Article 22, which is set on later dates. If you place a GPAI model on the EU market now, the representative has to be in place now. ## Where the representative must be established In the Union, and nowhere more specific. Article 3(5) defines an authorised representative as a natural or legal person located or established in the Union who has received and accepted a written mandate from a provider. Article 54(1) repeats the same requirement, established in the Union, without naming a Member State. Because there is no Member State constraint, Engage Compliance performs this role directly from its EU establishment. You do not need a representative set up in a particular country, and you do not need a chain of local entities. ## What the duties are The representative's obligations are set out in Article 54(3) and 54(5), and they are more than a mailbox: - **Hold the mandate for the AI Office.** Keep a copy of the written mandate and provide it to the AI Office on request, in one of the official languages of the institutions of the Union. - **Hold the technical documentation for ten years.** Keep a copy of the Annex XI technical documentation at the disposal of the AI Office and national competent authorities for 10 years after the model is placed on the market. That duty outlives the commercial relationship, so if the engagement ends in year two, the documents are still held for the remaining eight. - **Hold the provider's contact details** and be the point of contact for the provider on the model. - **Terminate and report if the provider is off side.** Under Article 54(5), the representative must terminate the mandate if it considers, or has reason to consider, that the provider is acting contrary to its obligations under the Regulation, and in that case it must immediately inform the AI Office of the termination and the reasons for it. That last duty is worth reading twice before you sign a mandate with anyone. It puts the representative under a legal obligation that can run against its own paying client, and it needs to be set out plainly in the engagement terms rather than discovered later. ## What the penalty is We would rather be honest about this than overstate it, because the position is genuinely awkward. There is no article that expressly fines a provider for failing to appoint the Article 54 representative. The fine keyed to authorised representatives in Article 99(4)(b), up to €15 million or 3 percent of worldwide annual turnover, is tied to the obligations of representatives under Article 22, the high-risk role, not Article 54. What does apply is Article 101. Chapter V is enforced by the Commission directly against the provider of the general-purpose AI model, with fines of up to 3 percent of worldwide annual turnover or €15 million, from 2 August 2026. So do not read this as an obligation without teeth. An operator under the AI Act is defined to include the authorised representative, and a national regulator could construct a penalty for an Article 54 breach on that basis, while the Commission can treat a failure to appoint as part of a provider's wider non-compliance. The safe reading is that the duty is live, it is enforceable against the provider, and the exact penalty route for the appointment itself is still developing. ## What Engage Compliance delivers - **Scoping first.** We confirm whether you are actually a GPAI provider under Article 54 or a deployer or downstream provider, before anything else. If you are not caught, we say so. - **The written mandate**, in a form that meets Article 54(1) and can be produced to the AI Office in an official EU language. - **Custody of the Annex XI technical documentation**, held at the disposal of the AI Office and national authorities for the full 10-year period. - **The named contact point** for the provider, established in the Union. - **Handling of AI Office and national authority contact**, with the substance passed to you and a recommended response. - **Clear engagement terms on the Article 54(5) termination duty**, so the one obligation that can run against you is understood and agreed at the start, not sprung later. Appointments of this kind are typically completed in a few working days once scoping is done. ## What it costs Pricing is scoped to the mandate. The work depends on the model, whether it sits above or below the systemic-risk line, and the state of your technical documentation, so we quote it rather than list it. Talk to us for a quote at [/contact](/contact). If your obligations run wider than the AI Act, the [EU AI Act compliance services](/eu-ai-act-compliance-services) overview sets out the surrounding work, and the [high-risk AI authorised representative](/ai-act-authorised-representative-high-risk) page covers the separate Article 22 role for high-risk AI systems. ## Sources and references - [EU AI Act, Article 54](https://ai-act-service-desk.ec.europa.eu/en/ai-act/article-54), European Commission AI Act Service Desk - [Regulation (EU) 2024/1689 (EU AI Act)](https://eur-lex.europa.eu/eli/reg/2024/1689/oj), EUR-Lex ## Frequently asked questions ### What is an AI Act authorised representative? It is a natural or legal person established in the Union, appointed by written mandate from a provider outside the EU, to act for that provider on its general-purpose AI model obligations. The role comes from Article 54 of the EU AI Act. The representative keeps a copy of the mandate for the AI Office, holds the Annex XI technical documentation at the disposal of the AI Office and national authorities for 10 years, and holds the provider's contact details. ### Who needs a GPAI authorised representative under Article 54? Providers established in third countries, before placing a general-purpose AI model on the Union market, must by written mandate appoint an authorised representative established in the Union. If you build and release a general-purpose AI model from outside the EU and it reaches the Union market, you are caught. Most SaaS companies are not, because running a feature on someone else's model makes you a deployer or a downstream provider, not the provider of the model. ### Is the open-source exemption real? Yes, but it is narrow. Providers of general-purpose AI models released under a free and open-source license that allows access, use, modification, and distribution, and whose parameters, weights, model architecture, and usage information are publicly available, are exempt from Article 54. The exemption falls away if the model presents systemic risks, in which case the appointment is required again. ### When did the Article 54 obligation start? Chapter V of the AI Act, which contains Article 54, applies from 2 August 2025. The duty to appoint a representative before placing a GPAI model on the Union market is in force now, which is why this is the part of the AI Act to deal with first. ### Where does the authorised representative have to be established? In the Union. Article 3(5) defines the authorised representative as a person located or established in the Union who has received and accepted a written mandate. No single Member State is required, so Engage Compliance provides the role directly from its EU establishment without a separate local entity. ### What is the penalty for not appointing one? There is no article that expressly fines a provider for failing to appoint the Article 54 representative. The fine tied to authorised representatives in Article 99(4)(b) covers the high-risk role under Article 22, not Article 54. Chapter V is enforced by the Commission against the provider under Article 101, up to 3 percent of worldwide annual turnover or €15 million, from 2 August 2026. An operator under the AI Act includes the authorised representative, so a regulator could construct a penalty, and this obligation should not be treated as unenforceable.