Direct answer
What obligations does the importer have under Article 23 of the AI Act?
Your question is about Article 23: obligations of importers. 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 importers of high-risk AI systems. For the standalone Annex III route (Article 6(2)) the date is 2 December 2027; for the embedded Annex I route (Article 6(1)) the date is 2 August 2028.
- If you put your own name or trade mark on the system, substantially modify it, or change the intended purpose so that it becomes high-risk, Article 25(1) treats you as a provider and the duties of Article 16 apply instead of those of Article 23.
First step: Run the four verifications of Article 23(1) before importing.
Article 23 of the AI Act covers obligations of importers. 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. The duty sits with the importer. This obligation starts to apply on 2 December 2027.
This applies now
- For this situation, the preparation phase matters most right now.
Coming up
- Article 23: obligations of importersfrom 2 December 2027
Your first actions
- 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.
Record this
- Importer dossier with ten-year retention
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
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