Direct answer
What obligations does the authorised representative and the provider of a GPAI model have under Article 54 of the AI Act?
Your question is about Article 54: authorised representative of a provider of a GPAI model. That obligation applies today. Whether your system actually falls under it depends on conditions you assess yourself.
You determine this yourself
- Applies where the model qualifies as a general-purpose AI model within the meaning of Article 3(63), its provider is established in a third country, and that model is placed on the Union market. The appointment is made by written mandate within the meaning of Article 3(5), which is not only given but also accepted, and it is made before the model is placed on the market. The moment at which the latter occurs is fixed less sharply for a model than for a system; see the editorial interpretation.
- For models placed on the market from 2 August 2025, the appointment duty applies from that moment. Providers of models placed on the market before 2 August 2025 shall, under Article 111(3), take the necessary steps to comply with the obligations of the Regulation by 2 August 2027.
- Paragraph 6 excludes the obligation for providers of AI models released under a free and open-source licence that allows access, usage, modification and distribution, and whose parameters, including the weights, the information on the model architecture and the information on model usage, are made publicly available. That exception falls away as soon as the model presents a systemic risk. Whether a given release qualifies is a factual test that has not been settled anywhere; we read it narrowly, so a partially public release does not qualify.
First step: Appoint an authorised representative and record the mandate.
Article 54 of the AI Act covers authorised representative of a provider of a GPAI model. A provider established in a third country appoints, by written mandate, an authorised representative established in the Union before placing a general-purpose AI model on the Union market. The representative performs the tasks the mandate assigns to it and provides a copy of that mandate to the AI Office upon request. The mandate empowers it at least to verify the documentation, keep a copy available for ten years, provide information and cooperate, and appoints it as the point of contact in addition to or instead of the provider. The duty sits with the authorised representative and the provider of a GPAI model. This obligation has applied since 2 August 2025.
This applies now
Your first actions
- 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.
Record this
- Mandate file of the authorised representative
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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