Direct answer
Which AI Act obligations apply to the AI value chain?
3 obligations under the AI Act bear on this, of which 0 apply today.
First step: Run the four verifications of Article 23(1) before importing.
The knowledge base holds 3 obligations for which the AI value chain is the duty holder. Of those, 0 apply today and 3 arrive later. Every obligation below points back to the official text, with the version and the date on which we verified it.
This applies now
- For this situation, the preparation phase matters most right 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
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.
- 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).
- Assess the value-chain role per system and change. On white-labelling, substantial modification or purpose change, assess whether your organisation becomes the provider, and arrange the representative for non-EU supply.
Record this
- Importer dossier with ten-year retention
- Distributor log of checks and corrective actions
- Value-chain file
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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