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What obligations does the provider of an AI system have under Article 21 of the AI Act?

Your question is about Article 21: cooperation with competent authorities. That obligation applies from 2 December 2027. Whether your system actually falls under it depends on conditions you assess yourself.

You determine this yourself

  • Applies to providers of high-risk AI systems as soon as a competent authority makes a reasoned request. For the standalone Annex III route (Article 6(2)) the date is 2 December 2027. For systems that are high-risk under Article 6(1) and relate to products covered by Annex I, Section A, the date is 2 August 2028. For products covered by Annex I, Section B, Article 21 does not apply at all: amended Article 2(2) makes only Article 6(1), Article 60a and Articles 102 to 112 applicable there, and Article 21 is not on that list. That is not a corner case, because the Machinery Regulation (EU) 2023/1230 has been moved from Section A to Section B. Note also the new Article 2(13): for systems under Annex I, Section A, the Commission may limit the application of Articles 17 to 25, and therefore of Article 21, by delegated act.
  • For systems already running, the amended Article 111(2) applies: without prejudice to the application of Article 5 as referred to in Article 113, third paragraph, point (a), the Regulation applies to operators of high-risk AI systems, other than those referred to in Article 111(1), placed on the market or put into service before the date of application of Chapter III referred to in Article 113, only if, as from that date, those systems are subject to significant changes in their designs. The reference date is therefore no longer 2 August 2026 but whichever date applies to the system: 2 December 2027 for the Annex III route and 2 August 2028 for the Annex I route. For systems intended to be used by public authorities the date of 2 August 2030 applies in any case.
  • What the authority obtains pursuant to this Article is treated in accordance with the confidentiality obligations of Article 78. That is not a limit on the duty to supply and therefore not an exception: it is how what you supplied is handled on the receiving side.
  • Paragraph 2 carries two limits, not one. Access to the automatically generated logs applies "as applicable", and it applies "to the extent such logs are under their control". Logs held solely by the deployer therefore fall outside what the provider can supply under this Article; the deployer keeps those logs itself under Article 26(6).

First step: Make your conformity file deliverable on request.

Article 21 of the AI Act covers cooperation with competent authorities. Upon a reasoned request by a competent authority, the provider of a high-risk AI system provides all the information and documentation necessary to demonstrate conformity with the requirements of Chapter III, Section 2, in a language which can be easily understood by the authority in one of the official languages of the institutions of the Union as indicated by the Member State concerned. Upon the same request the provider also gives, as applicable, access to the automatically generated logs, to the extent those logs are under its control. The duty sits with the provider of an AI system. This obligation starts to apply on 2 December 2027.

The conclusion and your first steps

This applies now

  • For this situation, the preparation phase matters most right now.

Coming up

Your first actions

  1. Make your conformity file deliverable on request. Map per high-risk system where each part of the file sits, which system version it belongs to, who assembles it, how long the logs are kept and in which language indicated by the Member State concerned you can supply it, so that a reasoned request becomes a delivery task rather than a search.
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

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 21(1)-(3)
    • Article 12(1); Article 19(1); Article 21(1)-(3); Article 22(3); Article 26(6); Article 74(1); Article 78; Article 99(5)
  • 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 (34), amending Article 77; Article 1, point (38)(b), inserting point (da) into Article 99(4)
    • Article 1, point (40)(b), replacing Article 113, third paragraph, point (c)
    • Article 1, point (39)(a), replacing Article 111(2)
    • Article 1, point (2)(a), replacing Article 2(2); Article 1, point (41), amending Annex I

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

Execution

Embed this obligation in policy, process and ownership

A legal action only works when it is clear who performs it, where the evidence sits and when it is reviewed. Embed AI translates this obligation into working agreements, controls and ownership per system. The source interpretation above is separate from this commercial referral by Praxikon to an affiliated brand.

See the governance approach
Does this answer your question?
Zahed Ashkara, jurist and freelance AI & Privacy Consultant

Behind this page

Zahed Ashkara

Freelance AI & Privacy Consultant, jurist