AI Act Article 54: Authorised representatives of providers of general-purpose AI models

What this article means in practice

Written by Engage Compliance. The text above is the article itself, reproduced from its official source and unchanged. Everything in this section is ours, and last read against the current text on 2026-09-07.

If you are established outside the EU and you place a general-purpose AI model on the Union market, Article 54 makes you appoint an authorised representative in the Union by written mandate before you place it. The representative verifies your Annex XI technical documentation, holds a copy of it for ten years, and is the party the AI Office can address instead of you.

Who it binds

• Providers of general-purpose AI models established in third countries, before placing the model on the Union market (Article 54(1)).
• It does not bind providers of models released under a genuinely free and open-source licence that allows access, use, modification and distribution, where the parameters including the weights, the architecture information and the usage information are all publicly available (Article 54(6)).
• That exemption falls away entirely where the model presents systemic risk (Article 54(6)). An open-weights model over the systemic-risk threshold needs a representative like any other.
• It does not bind providers established in the Union, and it does not bind downstream deployers who integrate someone else's model.

What it makes somebody do

• You, the provider. Appoint the authorised representative by written mandate before placing the model on the Union market (Article 54(1)).
• You, the provider. Enable the representative to perform the tasks the mandate specifies (Article 54(2)).
• The representative. Verify that the Annex XI technical documentation has been drawn up and that the Article 53 obligations, and Article 55 where it applies, have been fulfilled by you (Article 54(3)(a)).
• The representative. Keep a copy of the Annex XI technical documentation and your contact details at the disposal of the AI Office and national competent authorities for ten years after the model is placed on the market (Article 54(3)(b)).
• The representative. On a reasoned request, provide the AI Office with everything needed to demonstrate compliance with the Chapter's obligations (Article 54(3)(c)).
• The representative. Cooperate with the AI Office and competent authorities on any action about the model, including where the model has been integrated into systems already on the Union market (Article 54(3)(d)).
• The representative. Provide a copy of the mandate to the AI Office on request, in an official language of the Union institutions (Article 54(3)).
• The representative. Terminate the mandate and immediately tell the AI Office why, if it considers or has reason to consider you are acting contrary to the Regulation (Article 54(5)).

What it does not say

• It does not make the representative liable for the model. The tasks are verification of whether documentation exists, custody, disclosure and cooperation, and Article 54 does not transfer the Article 53 obligations onto the representative.
• Verification under Article 54(3)(a) is not an audit of the model. The provision asks whether the documentation has been drawn up and the obligations fulfilled, and prescribes no method, depth or frequency for establishing it.
• The Article 54(6) exemption is not an open-source exemption in the loose sense. All four conditions have to hold together: the terms the model is released under, the weights, the architecture information and the usage information, every one of them publicly available.
• It is not the same trigger as Article 22. Article 54 turns on placing a MODEL on the market; Article 22 turns on making a high-risk SYSTEM available. A company can do both.
• The counterparty is different from Article 22. Here the representative is addressed by the AI Office, which is a Union body, rather than only by national market surveillance authorities.

How it sits beside the other mandates

• Article 53 is what the representative is verifying against. Reading Article 54 without Article 53 gives you the appointment and not the thing it is an appointment about.
• Where a model presents systemic risk, Article 55 adds obligations and the Article 54(6) open-source exemption stops applying, so the systemic-risk question decides whether this article binds you at all.
• A provider that both ships a model and puts a high-risk system on the market needs Article 54 and Article 22, and the ten-year custody periods run from two different dates.