Direct answer
What does the AI value chain actually have to do under the AI Act?
3 obligations under the AI Act bear on this, of which 0 apply today.
First step: Run the four verifications of Article 23(1) before importing.
The 3 obligations for the AI value chain produce 3 concrete actions. Each action below belongs to a provision, carries its own conditions and names the date by which it has to be done.
The conclusion and your first steps
This applies now
- For this situation, the preparation phase matters most right now.
Coming up
- Article 23: obligations of importersfrom 2 December 2027
- Article 24: obligations of distributorsfrom 2 December 2027
- Articles 22-25: value chain and authorised representativefrom 2 December 2027
What you have to do
- Run the four verifications of Article 23(1) before importing. 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.
- Perform the Article 24(1) check before making available. 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).
- Assess the value-chain role per system and change. On white-labelling, substantial modification or purpose change, assess whether your organisation becomes the provider, and arrange the representative for non-EU supply.
Read the official sourceChecked on
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situation