Direct answer
What obligations does the distributor have under Article 24 of the AI Act?
Your question is about Article 24: obligations of distributors. 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 distributors 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 24.
First step: Perform the Article 24(1) check before making available.
Article 24 of the AI Act covers obligations of distributors. 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. The duty sits with the distributor. 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 24: obligations of distributorsfrom 2 December 2027
Your first actions
- 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).
Record this
- Distributor log of checks and corrective actions
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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