{"answer_id":"praxikon:eu:ai-act:answer:verplichtingen-waardeketen-ai-act","canonical_page":"https://www.praxikon.com/en/antwoord/verplichtingen-waardeketen-ai-act","query":"Which AI Act obligations apply to the AI value chain?","lang":"en","view":"full","mode":"form","question":"Which AI Act obligations apply to the AI value chain?","situation":"The knowledge base holds 3 obligations for which the AI value chain is the duty holder. Of those, 0 apply today and 3 arrive later. Every obligation below points back to the official text, with the version and the date on which we verified it.","likely_role":null,"note":null,"matched_terms":[],"dataset":{"id":"praxikon:sys:registry:dataset:ai-act-implementation-graph","version":"2.1.0","schema_version":"1.4.0","effective_at":"2026-08-08T00:00:00.000Z","known_at":"2026-08-14T00:00:00.000Z","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-23-importer-obligations","label":"Article 23: obligations of importers","summary":"Before placing a system on the market the importer verifies four things about the provider, and afterwards carries its own retention, information and notification package with a ten-year term.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","human_page":"https://www.praxikon.com/en/verplichtingen/article-23-importer-obligations","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":"Article 23(1) requires importers, before placing a high-risk AI system on the market, to verify that the relevant conformity assessment procedure referred to in Article 43 has been carried out by the provider (point (a)), that the provider has drawn up the technical documentation in accordance with Article 11 and Annex IV (point (b)), that the system bears the required CE marking and is accompanied by the EU declaration of conformity referred to in Article 47 and instructions for use (point (c)), and that the provider has appointed an authorised representative in accordance with Article 22(1) (point (d)). Article 23(2) provides that an importer with sufficient reason to consider that the system is not in conformity, is falsified or is accompanied by falsified documentation shall not place it on the market until it has been brought into conformity, and that where the system presents a risk within the meaning of Article 79(1) the importer shall inform the provider, the authorised representative and the market surveillance authorities. Paragraph 3 requires indication of name, registered trade name or registered trade mark and contact address. Paragraph 4 requires storage and transport conditions that do not jeopardise compliance with Section 2. Paragraph 5 requires keeping, for 10 years, a copy of the certificate issued by the notified body and, where applicable, of the instructions for use and of the EU declaration of conformity referred to in Article 47. Paragraph 6 requires providing all necessary information and documentation upon a reasoned request in a language easily understood by the authority, and ensuring the technical documentation can be made available. Paragraph 7 requires cooperation with the competent authorities.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 23(1)-(7)","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":"Article 23 gets underestimated because it looks like document control, and largely it is: you do not have to revalidate the model, you have to be able to show that you checked the four points. The pain sits elsewhere. Point (d) is the one that most often fails in practice: many providers outside the EU have not appointed an authorised representative, and then you simply may not place the system on the market, however far along the deal is. And paragraph 5 puts the ten-year term on you, not on the supplier: if that supplier no longer exists in five years, you still have to produce the documents.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 23(1)-(7)","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":"Move the four verifications of Article 23(1) to the moment before contract signature instead of before delivery. Request the declaration of conformity, the technical documentation, proof of the Article 43 procedure and the authorised representative's details as a condition precedent in the purchase contract.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 23(1)-(7)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"article-24-distributor-obligations","label":"Article 24: obligations of distributors","summary":"Before making a system available on the market the distributor verifies the marking, the declaration and the instructions for use plus compliance by provider and importer, and must afterwards be able to correct, withdraw or recall.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","human_page":"https://www.praxikon.com/en/verplichtingen/article-24-distributor-obligations","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":"Article 24(1) requires distributors, before making a high-risk AI system available on the market, to verify that it bears the required CE marking, that it is accompanied by a copy of the EU declaration of conformity referred to in Article 47 and instructions for use, and that the provider and the importer of that system, as applicable, have complied with their obligations laid down in Article 16, points (b) and (c), and Article 23(3). Paragraph 2 prohibits making the system available while the distributor considers or has reason to consider, on the basis of the information in its possession, that it does not comply with the requirements of Section 2, and requires notification of the provider or the importer where the system presents a risk within the meaning of Article 79(1). Paragraph 3 requires storage and transport conditions that do not jeopardise compliance. Paragraph 4 requires a distributor that considers or has reason to consider that a system already made available does not comply with Section 2 to take the corrective actions necessary to bring it into conformity, to withdraw it or recall it, or to ensure that the provider, the importer or any relevant operator takes those actions; where the system presents a risk within the meaning of Article 79(1) it shall immediately inform the provider or importer and the competent authorities, giving details of the non-compliance and of any corrective actions taken. Paragraph 5 requires providing, upon a reasoned request, all information and documentation regarding actions taken under paragraphs 1 to 4. Paragraph 6 requires cooperation with the competent authorities.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 24(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":"The check in paragraph 1 looks light but contains an awkward element: you must also verify that the provider has complied with Article 16, point (c), which is having a quality management system in place under Article 17. You cannot see that on the packaging. In practice you anchor it in supplier terms with a statement from the provider and record what you checked. The centre of gravity of Article 24 sits in paragraph 4 though: many resellers assume recall is the manufacturer's business, while the provision also places that action on you, with the option of ensuring another party carries it out. That ensuring requires contractual grip arranged in advance, not during an incident.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 24(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":"Include the three checks of paragraph 1 in your resell or delivery process and keep a record per contract of what you saw. Also make sure you can tell within a day which customer uses which system in which version, because without that overview you cannot execute paragraph 4.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Article 24(1)-(6)","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]},{"slug":"value-chain-representative","label":"Articles 22-25: value chain and authorised representative","summary":"Role shifts in the AI value chain and the mandatory representative for non-EU providers.","legal_status":"upcoming","deadline_at":"2027-12-02T00:00:00.000Z","human_page":"https://www.praxikon.com/en/verplichtingen/value-chain-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":"Article 25 provides that a distributor, importer, deployer or third party becomes the provider when it puts its name on a high-risk system, substantially modifies it or changes its intended purpose so it becomes high-risk; Article 22 obliges third-country providers to appoint a written authorised representative in the Union.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Articles 22 and 25","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":"For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.","source_id":"praxikon:eu:ai-act:source:reg-eu-2026-1744","source_locator":"Amended Article 113 application dates","source_url":"https://eur-lex.europa.eu/eli/reg/2026/1744/oj","eli":"http://data.europa.eu/eli/reg/2026/1744/oj"},{"kind":"editorial_interpretation","statement":"The most dangerous role switch is the unintended one: your own layer on top of a procured model, your own brand on a tool, and you suddenly carry the full provider duties. This belongs as a standing question in every AI project.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Articles 22 and 25","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":"Include the role question in the AI register and in project gates, and contractually define who supplies which information and cooperation on changes.","source_id":"praxikon:eu:ai-act:source:reg-eu-2024-1689","source_locator":"Articles 22 and 25","source_url":"https://eur-lex.europa.eu/eli/reg/2024/1689/oj","eli":"http://data.europa.eu/eli/reg/2024/1689/oj"}]}],"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":"Run the four verifications of Article 23(1) before importing","summary":"Check and record: the conformity assessment has been carried out, the technical documentation exists, the CE marking plus declaration and instructions for use are present, and an authorised representative has been appointed."},{"label":"Perform the Article 24(1) check before making available","summary":"Verify the CE marking, the presence of the EU declaration of conformity and the instructions for use, and whether the provider and importer complied with Article 16, points (b) and (c), and Article 23(3)."},{"label":"Assess the value-chain role per system and change","summary":"On white-labelling, substantial modification or purpose change, assess whether your organisation becomes the provider, and arrange the representative for non-EU supply."}],"evidence":[{"label":"Importer dossier with ten-year retention","summary":"Your own archive of the notified body certificate, the instructions for use and the EU declaration of conformity, available for ten years and in a language the authority easily understands.","url":null},{"label":"Distributor log of checks and corrective actions","summary":"A running record of what you checked, when, with what outcome and which action followed, because the supervisor asks about your conduct rather than about the system.","url":null},{"label":"Value-chain file","summary":"Record per system of role, contractual arrangements on information and cooperation, and the appointment of a representative where required.","url":null}],"guidance":[],"examples":[],"standards":[],"definitions":[],"answer_page":"https://www.praxikon.com/en/antwoord/verplichtingen-waardeketen-ai-act","follow_up_questions":[{"question":"We source AI from outside the EU. What do we need to arrange?","url":"https://www.praxikon.com/en/antwoord/ai-inkopen-buiten-de-eu"}],"disclaimer":"General interpretation, not legal advice. The official source remains authoritative.","methodology":"https://www.praxikon.com/en/methodologie"}