{"answer_id":"praxikon:eu:ai-act:answer:artikel-54-ai-act","canonical_page":"https://www.praxikon.com/en/antwoord/artikel-54-ai-act","query":"What obligations does the authorised representative and the provider of a GPAI model have under Article 54 of the AI Act?","lang":"en","view":"full","mode":"obligation","question":"What obligations does the authorised representative and the provider of a GPAI model have under Article 54 of the AI Act?","situation":"Article 54 of the AI Act covers authorised representative of a provider of a GPAI model. A provider established in a third country appoints, by written mandate, an authorised representative established in the Union before placing a general-purpose AI model on the Union market. The representative performs the tasks the mandate assigns to it and provides a copy of that mandate to the AI Office upon request. The mandate empowers it at least to verify the documentation, keep a copy available for ten years, provide information and cooperate, and appoints it as the point of contact in addition to or instead of the provider. The duty sits with the authorised representative and the provider of a GPAI model. This obligation has applied since 2 August 2025.","likely_role":null,"note":null,"matched_terms":[],"dataset":{"id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","version":"2.2.0","schema_version":"1.5.0","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-09-06T00:00:00.000Z","last_reviewed_at":"2026-08-08T00:00:00.000Z","licence":"https://www.praxikon.com/nl/legal/terms","canonical_url":"https://www.praxikon.com/api/v1/entities"},"obligations":[{"slug":"article-54-gpai-authorised-representative","label":"Article 54: authorised representative of a provider of a GPAI model","summary":"A provider established in a third country appoints, by written mandate, an authorised representative established in the Union before placing a general-purpose AI model on the Union market. The representative performs the tasks the mandate assigns to it and provides a copy of that mandate to the AI Office upon request. The mandate empowers it at least to verify the documentation, keep a copy available for ten years, provide information and cooperate, and appoints it as the point of contact in addition to or instead of the provider.","legal_status":"applicable","deadline_at":"2025-08-02T00:00:00.000Z","high_risk_regime_from":null,"human_page":"https://www.praxikon.com/en/verplichtingen/article-54-gpai-authorised-representative","api":"https://www.praxikon.com/api/v1/obligations?lang=en","official_source":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","citations":[{"kind":"official_fact","statement":"Paragraph 1 provides that, prior to placing a general-purpose AI model on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union. Paragraph 2 provides that the provider shall enable its authorised representative to perform the tasks specified in the mandate received from the provider. Paragraph 3 provides that the authorised representative shall perform the tasks specified in the mandate received from the provider, that it shall provide a copy of the mandate to the AI Office upon request in one of the official languages of the institutions of the Union, and that for the purposes of the Regulation the mandate shall empower the authorised representative to carry out the following tasks: (a) verify that the technical documentation specified in Annex XI has been drawn up and all obligations referred to in Article 53 and, where applicable, Article 55 have been fulfilled by the provider; (b) keep a copy of the technical documentation specified in Annex XI at the disposal of the AI Office and national competent authorities, for a period of 10 years after the general-purpose AI model has been placed on the market, and the contact details of the provider that appointed the authorised representative; (c) provide the AI Office, upon a reasoned request, with all the information and documentation, including that referred to in point (b), necessary to demonstrate compliance with the obligations in that Chapter; (d) cooperate with the AI Office and competent authorities, upon a reasoned request, in any action they take in relation to the general-purpose AI model, including when the model is integrated into AI systems placed on the market or put into service in the Union. Paragraph 4 provides that the mandate shall empower the authorised representative to be addressed, in addition to or instead of the provider, by the AI Office or the competent authorities, on all issues related to ensuring compliance with the Regulation. Paragraph 5 provides that the authorised representative shall terminate the mandate if it considers or has reason to consider the provider to be acting contrary to its obligations pursuant to the Regulation, and that in such a case it shall also immediately inform the AI Office about the termination of the mandate and the reasons therefor. Paragraph 6 provides that the obligation set out in that Article shall not apply to providers of general-purpose AI models that are released under a free and open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available, unless the general-purpose AI models present systemic risks.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 54(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"Paragraph 1 provides that, prior to placing a general-purpose AI model on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union. Paragraph 2 provides that the provider shall enable its authorised representative to perform the tasks specified in the mandate received from the provider. Paragraph 3 provides that the authorised representative shall perform the tasks specified in the mandate received from the provider, that it shall provide a copy of the mandate to the AI Office upon request in one of the official languages of the institutions of the Union, and that for the purposes of the Regulation the mandate shall empower the authorised representative to carry out the following tasks: (a) verify that the technical documentation specified in Annex XI has been drawn up and all obligations referred to in Article 53 and, where applicable, Article 55 have been fulfilled by the provider; (b) keep a copy of the technical documentation specified in Annex XI at the disposal of the AI Office and national competent authorities, for a period of 10 years after the general-purpose AI model has been placed on the market, and the contact details of the provider that appointed the authorised representative; (c) provide the AI Office, upon a reasoned request, with all the information and documentation, including that referred to in point (b), necessary to demonstrate compliance with the obligations in that Chapter; (d) cooperate with the AI Office and competent authorities, upon a reasoned request, in any action they take in relation to the general-purpose AI model, including when the model is integrated into AI systems placed on the market or put into service in the Union. Paragraph 4 provides that the mandate shall empower the authorised representative to be addressed, in addition to or instead of the provider, by the AI Office or the competent authorities, on all issues related to ensuring compliance with the Regulation. Paragraph 5 provides that the authorised representative shall terminate the mandate if it considers or has reason to consider the provider to be acting contrary to its obligations pursuant to the Regulation, and that in such a case it shall also immediately inform the AI Office about the termination of the mandate and the reasons therefor. Paragraph 6 provides that the obligation set out in that Article shall not apply to providers of general-purpose AI models that are released under a free and open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available, unless the general-purpose AI models present systemic risks.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 3(5)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"Article 113(3)(b) provides that Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101. Article 54 sits in Chapter V and therefore applies from 2 August 2025.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 113(3)(b)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"Article 101(1) provides that the Commission may impose on providers of general-purpose AI models fines not exceeding 3 percent of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000, whichever is higher. Article 101 is excluded by Article 113(3)(b) from the earlier application of Chapter XII and has therefore applied since 2 August 2026. The obligation in Article 54 has thus applied since 2 August 2025, while the Commission fining power behind it exists only since 2 August 2026.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 101(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"official_fact","statement":"Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in the Regulation by 2 August 2027.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 111(3)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"This article touches two parties that rarely see themselves that way. The first is the model provider outside the Union that assumes nothing is required until a European customer asks: paragraph 1 places the appointment before the placing on the market, so the representative should exist before the first user in the Union can access the model. The second is the European party that accepts the mandate. It is not stepping into a mailbox role, but note how paragraph 3 is built: the first sentence obliges it to perform the tasks the mandate assigns to it, and only then does the article list what the mandate empowers it to do. Points (a) to (d) are therefore mandate content and empowerment, and its duty runs through them. That is where this article leaves its sharpest question open: is a representative that accepts a mandate omitting task (a) or (b) itself in breach, or does the failure rest entirely with the provider that drew up the mandate. We read paragraph 3 as making the list mandatory minimum content, so that a mandate lacking it does not satisfy the article, which leaves the provider answerable under paragraph 1 and the representative answerable for what it did accept. A defensible alternative reading is that a representative signing without those powers takes on a task it cannot discharge and thereby falls short itself. So do not assume the ten year retention in point (b) rests on you automatically, or automatically does not; write it out. Paragraph 5 closes this off in a way that is often missed: a representative that considers, or has reason to consider, that the provider is breaching its obligations terminates the mandate and immediately informs the AI Office. That is a duty rather than a power, and it calls for access to the documentation agreed in advance and for a moment at which that access is tested.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 54(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"Three things about the timeline and the scope. First, the difference between duty and enforcement: the duty has applied since 2 August 2025, but Article 101 is excluded from the earlier application, so the Commission can only fine since 2 August 2026. For a provider outside the Union discovering today that it has no representative, that means: in breach for well over a year, and now also exposed to a fine. Second, the relationship with Article 22. That article carries the same figure for high-risk AI systems, starting on 2 December 2027 and 2 August 2028; Article 54 is the separate route for general-purpose AI models and has applied since 2 August 2025. Anyone looking up the role of authorised representative finds both and needs to know which route applies. Third, the trigger in paragraph 1. The Regulation fixes the moment of placing on the market less sharply for a model than for a system, and for a model made available only through an interface from a third country there is no case law. We read the duty as starting once the model is made available to users in the Union in the course of a commercial activity, because paragraph 1 attaches to placing on the market and not to establishment in the Union. A defensible alternative reading is that making a model available through an interface is not placing the model itself on the market, so that the duty only arises on an actual supply of the model.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 113(3)(b)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"editorial_interpretation","statement":"Three things about the timeline and the scope. First, the difference between duty and enforcement: the duty has applied since 2 August 2025, but Article 101 is excluded from the earlier application, so the Commission can only fine since 2 August 2026. For a provider outside the Union discovering today that it has no representative, that means: in breach for well over a year, and now also exposed to a fine. Second, the relationship with Article 22. That article carries the same figure for high-risk AI systems, starting on 2 December 2027 and 2 August 2028; Article 54 is the separate route for general-purpose AI models and has applied since 2 August 2025. Anyone looking up the role of authorised representative finds both and needs to know which route applies. Third, the trigger in paragraph 1. The Regulation fixes the moment of placing on the market less sharply for a model than for a system, and for a model made available only through an interface from a third country there is no case law. We read the duty as starting once the model is made available to users in the Union in the course of a commercial activity, because paragraph 1 attaches to placing on the market and not to establishment in the Union. A defensible alternative reading is that making a model available through an interface is not placing the model itself on the market, so that the duty only arises on an actual supply of the model.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"recommended_action","statement":"First establish whether you are the provider of the model or only a user, because only the provider appoints. If you are established outside the Union, put the mandate in writing before the model becomes available here, and write the four tasks in paragraph 3 into it expressly, together with the access to the Annex XI documentation and the point of contact under paragraph 4. If your model was already on the market before 2 August 2025, work to 2 August 2027 rather than to today. If you are only now discovering that there is no representative, assume the duty has run since 2 August 2025 and that the Commission has been able to fine since 2 August 2026; remedy first and record when you did. If you accept a mandate, agree in advance how you carry out the verification in paragraph 3(a), who holds the copy for ten years, and at what moment you test whether termination under paragraph 5 is called for.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 54(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"},{"kind":"recommended_action","statement":"First establish whether you are the provider of the model or only a user, because only the provider appoints. If you are established outside the Union, put the mandate in writing before the model becomes available here, and write the four tasks in paragraph 3 into it expressly, together with the access to the Annex XI documentation and the point of contact under paragraph 4. If your model was already on the market before 2 August 2025, work to 2 August 2027 rather than to today. If you are only now discovering that there is no representative, assume the duty has run since 2 August 2025 and that the Commission has been able to fine since 2 August 2026; remedy first and record when you did. If you accept a mandate, agree in advance how you carry out the verification in paragraph 3(a), who holds the copy for ten years, and at what moment you test whether termination under paragraph 5 is called for.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 101(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]}],"conditional":[],"sources":[{"id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","title":"EU Artificial Intelligence Act 2024/1689","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj","source_version":"original-oj-2024-07-12","verified_at":"2026-08-08T00:00:00.000Z"},{"id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","title":"Digital Omnibus on AI 2026/1744","publisher":"European Parliament and Council","canonical_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj","source_version":"official-journal-2026-07-24","verified_at":"2026-08-08T00:00:00.000Z"}],"first_actions":[{"label":"Appoint an authorised representative and record the mandate","summary":"Determine whether you are the provider of the model, appoint an authorised representative established in the Union by written mandate before placing the model on the market, and write out in that mandate the four tasks in paragraph 3, the access to the Annex XI documentation and the point of contact under paragraph 4."}],"evidence":[{"label":"Mandate file of the authorised representative","summary":"The written mandate itself, in an official language of the institutions of the Union, together with the copy of the Annex XI technical documentation, the contact details of the provider, and the record of the verification under paragraph 3(a). The provider grants the mandate and supplies the documentation; the ten year retention after the placing on the market rests under paragraph 3(b) with the representative, which keeps the file at the disposal of the AI Office and national competent authorities.","url":null}],"guidance":[],"examples":[],"standards":[],"definitions":[],"answer_page":"https://www.praxikon.com/en/antwoord/artikel-54-ai-act","follow_up_questions":[],"disclaimer":"General interpretation, not legal advice. The official source remains authoritative.","methodology":"https://www.praxikon.com/en/methodologie"}