{"answer_id":"praxikon:eu:ai-act:answer:wanneer-waardeketen-ai-act","canonical_page":"https://www.praxikon.com/en/antwoord/wanneer-waardeketen-ai-act","query":"When do the AI Act obligations start to apply to the AI value chain?","lang":"en","view":"full","mode":"form","question":"When do the AI Act obligations start to apply to the AI value chain?","situation":"The obligations for the AI value chain do not all start on the same day. They spread over 2 groups, from 2 August 2025 to 2 December 2027. Below is when each provision starts to apply.","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-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","high_risk_regime_from":null,"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","high_risk_regime_from":null,"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":"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"}]},{"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","high_risk_regime_from":null,"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"}]}],"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":"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":"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":"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":"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/wanneer-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"}