Direct answer
What evidence does the AI value chain have to be able to show 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.
To show that the AI value chain complies with the AI Act, 3 dossiers are required. Below is what belongs in each dossier and which obligation it follows from.
This applies now
Coming up
- Article 23: obligations of importersfrom 2 December 2027
- Article 24: obligations of distributorsfrom 2 December 2027
- Articles 22-25: value chain and authorised representativefrom 2 December 2027
What you have to be able to show
- Importer dossier with ten-year retention
Your own archive of the notified body certificate, the instructions for use and the EU declaration of conformity, available for ten years and in a language the authority easily understands.
- Distributor log of checks and corrective actions
A running record of what you checked, when, with what outcome and which action followed, because the supervisor asks about your conduct rather than about the system.
- Mandate file of the authorised representative
The written mandate itself, in an official language of the institutions of the Union, together with the copy of the Annex XI technical documentation, the contact details of the provider, and the record of the verification under paragraph 3(a). The provider grants the mandate and supplies the documentation; the ten year retention after the placing on the market rests under paragraph 3(b) with the representative, which keeps the file at the disposal of the AI Office and national competent authorities.
A dossier is not a document but a demonstrable whole: who maintains it, where it lives and when it was last updated.
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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