Map of the AI Act

Importer

The map shows what hangs off this object: who carries the duty, what it calls for, what it is evidenced by and what it rests on. Click an object and it becomes the new centre.

On a small screen the map reads as a path rather than as a network.

role

Importer

You are an importer as soon as you, from within the EU, first place an AI system on the Union market that bears the name or trade mark of a party established outside the EU. What counts is not your purchasing role but whose brand is on the system and who first brings it to market.

based on

Article 23 on EUR-Lexguidance

Legendroleobligationactionevidencesolid line: official findingdashed line: our reading

Back to the whole regulation

role

Importer

The legal path

Source ·: Article 23 on EUR-Lex
Condition ·: Applies where you are located or established in the Union and are the first to place an AI system from a third-country provider on the Union market under that provider's name or trade mark.
Exception ·: You are not an importer but a provider as soon as you put your own name or trade mark on the system, make a substantial modification, or change the intended purpose so that the system becomes high-risk (Article 25(1)(a), (b) and (c)). Point (a) expressly applies without prejudice to contractual arrangements stipulating that the obligations are otherwise allocated. The role switch can be determined today; the twelve duties of Article 16 start to apply on 2 December 2027 for the standalone Annex III route and on 2 August 2028 for the embedded Annex I route.

Open in the explorer

Checked on 2026-08-08T00:00:00.000Z · praxikon:eu:ai-act:actor:importer

Read the map atin force now 2 Feb 2025 2 Aug 2025 27 Jul 2026 2 Aug 2026 2 Dec 2026 2 Aug 2027 2 Dec 2027 2 Aug 2028

Read at 2 Dec 2027. What did not yet apply on that date is not shown here. The requirements for high-risk systems under Annex III apply, together with the FRIA.