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What does the AI value chain actually have to do under the AI Act?

4 obligations under the AI Act bear on this, of which 1 applies today.

First step: Run the four verifications of Article 23(1) before importing.

The 4 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

Coming up

What you have to do

  1. 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.
  2. 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).
  3. Appoint an authorised representative and record the mandate. 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.
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

Your route

From your situation, via your role, to what applies and when it starts.

1 now · 3 later

Your situation

The 4 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.

Applies now

From 2 December 2027

To record: Importer dossier with ten-year retention · Distributor log of checks and corrective actions · Mandate file of the authorised representative

Source and locator

Every statement above rests on these texts. The locator points to the place in the text, the version and the date say which edition was checked.

  • EU Artificial Intelligence Act 2024/1689

    European Parliament and Council, version original-oj-2024-07-12, checked on , ELI http://data.europa.eu/eli/reg/2024/1689/oj

    Locators in this source

    • Article 23(1)-(7)
    • Article 24(1)-(6)
    • Article 54(1)-(6)
    • Article 3(5)
    • Article 113(3)(b)
    • Article 101(1)-(6)
    • Article 111(3)
    • Articles 22 and 25

  • Digital Omnibus on AI 2026/1744

    European Parliament and Council, version official-journal-2026-07-24, checked on , ELI http://data.europa.eu/eli/reg/2026/1744/oj

    Locators in this source

    • Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)
    • Amended Article 113 application dates

Dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0, schema 1.5.0.

Execution

Make supplier information and commitments verifiable

Your own file partly depends on information, instructions and commitments from the provider or supplier. Embed AI checks which materials are missing and translates those gaps into contractual and operational actions. The source interpretation above is separate from this commercial referral by Praxikon to an affiliated brand.

See the vendor and contract approach
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Zahed Ashkara, jurist and freelance AI & Privacy Consultant

Behind this page

Zahed Ashkara

Freelance AI & Privacy Consultant, jurist

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