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ObligationUpcomingv1.0.0

Article 23: obligations of importers

Before placing a system on the market the importer verifies four things about the provider, and afterwards carries its own retention, information and notification package with a ten-year term.

The official source remains authoritative. This is general information about obligations and not legal advice. See this object on the map

Address and citation

This object has an address of its own that is never renamed or reused. Store the identifier in your own file, not the title or the link.

Identifier
praxikon:eu:ai-act:obligation:article-23-importer-obligations
Payload hash (sha256)
1a3e0958b87d5b96c66eb024898d343fb1a7f570e3fcffbfe56521278f17b278

Citation line

Praxikon, "Article 23: obligations of importers", praxikon:eu:ai-act:obligation:article-23-importer-obligations@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z, sha256 1a3e0958b87d5b96c66eb024898d343fb1a7f570e3fcffbfe56521278f17b278
Version
1.0.0
Legal time (effective_at)
8 August 2026
Knowledge time (known_at)
8 August 2026
Closed on
Not closed
Application date
2 December 2027
Topics
value-chain

Review status: Placed against the official source (8 August 2026). Next check due by 4 February 2027. The check date is the knowledge date of this version; no later recheck has been recorded.

Who must act and who is affected

On an obligation the addressee is recorded separately from the party that is merely affected. That difference decides who a supervisory authority addresses and who has work to do without the duty resting on them.

Duty holder

  • Importerpraxikon:eu:ai-act:actor:importer

Affected actor

Not recorded on this object.

Oversight

Evidence owner

  • Importerpraxikon:eu:ai-act:actor:importer

What this object links to

Every relation appears below as a path: from the source with its locator, through the conditions and exceptions of the object carrying the relation, to the consequence. A locator belongs to a statement in the data and not to a relation, so the source is the source anchor of the carrying object.

Who carries the duty

1 of 1 shown

The duty rests on this role. A supervisory authority addresses this role when it is not met.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

    • ActorImporter

      praxikon:eu:ai-act:actor:importer

Who supervises this

1 of 1 shown

This role supervises and receives the notifications. It is the institutional role, not the national body that fills it.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Who owns the evidence

1 of 1 shown

This duty holder creates, maintains and can produce the evidence.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

    • ActorImporter

      praxikon:eu:ai-act:actor:importer

What has to be done

1 of 1 shown

This is what concretely has to be done under the obligation.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What has to be recorded

1 of 1 shown

This is what has to be in the file to show that the action was carried out.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What keeps it in place

1 of 1 shown

This is what keeps compliance in place over time, periodic or event-driven.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

Public tools

1 of 1 shown

This is the public route a reader can actually use.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allApplies to importers 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.
    • ExceptionIf 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 23.

    As long as this exception is not ruled out, the outcome stays conditional and you have to establish it yourself.

    Consequence

What points at this object

Objects hanging off this obligation

4 of 4 shown

The object belongs to this obligation. The source line it hangs off sits there.

  1. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allTo be carried out before every first placing on the market of a high-risk AI system from a third-country provider.

    Relation recorded on: Run the four verifications of Article 23(1) before importing

    Consequence

  2. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allTriggered at the threshold of sufficient reason to consider, meaning on a well-founded signal and not only upon certainty or third-party confirmation.

    Relation recorded on: Stop rule and notification route on doubts about conformity

    Consequence

  3. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    • Condition | allThe ten-year term runs from placing on the market or putting into service, and therefore per system and per version, not per supplier relationship.

    Relation recorded on: Importer dossier with ten-year retention

    Consequence

  4. Source

    This object carries no official fact of its own. The source line below sits on the obligation it hangs off; the link itself is recorded editorially.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 23(1)-(7)

      praxikon:eu:ai-act:source:reg-eu-2024-1689

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Full text of Article 23

    Consequence

What this object states

Official fact

Attributable to a named primary source, with a locator. Where they differ, the official source prevails.

  • Article 23(1) requires importers, before placing a high-risk AI system on the market, to verify that the relevant conformity assessment procedure referred to in Article 43 has been carried out by the provider (point (a)), that the provider has drawn up the technical documentation in accordance with Article 11 and Annex IV (point (b)), that the system bears the required CE marking and is accompanied by the EU declaration of conformity referred to in Article 47 and instructions for use (point (c)), and that the provider has appointed an authorised representative in accordance with Article 22(1) (point (d)). Article 23(2) provides that an importer with sufficient reason to consider that the system is not in conformity, is falsified or is accompanied by falsified documentation shall not place it on the market until it has been brought into conformity, and that where the system presents a risk within the meaning of Article 79(1) the importer shall inform the provider, the authorised representative and the market surveillance authorities. Paragraph 3 requires indication of name, registered trade name or registered trade mark and contact address. Paragraph 4 requires storage and transport conditions that do not jeopardise compliance with Section 2. Paragraph 5 requires keeping, for 10 years, a copy of the certificate issued by the notified body and, where applicable, of the instructions for use and of the EU declaration of conformity referred to in Article 47. Paragraph 6 requires providing all necessary information and documentation upon a reasoned request in a language easily understood by the authority, and ensuring the technical documentation can be made available. Paragraph 7 requires cooperation with the competent authorities.

Our interpretation

Our own reading. It can change without the law changing, and it is not the position of a supervisory authority.

  • Article 23 gets underestimated because it looks like document control, and largely it is: you do not have to revalidate the model, you have to be able to show that you checked the four points. The pain sits elsewhere. Point (d) is the one that most often fails in practice: many providers outside the EU have not appointed an authorised representative, and then you simply may not place the system on the market, however far along the deal is. And paragraph 5 puts the ten-year term on you, not on the supplier: if that supplier no longer exists in five years, you still have to produce the documents.

Recommended step

A practical step we consider appropriate. Not an obligation following from the Regulation.

  • Move the four verifications of Article 23(1) to the moment before contract signature instead of before delivery. Request the declaration of conformity, the technical documentation, proof of the Article 43 procedure and the authorised representative's details as a condition precedent in the purchase contract.

When this applies

  1. 1Applies to importers 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.

When this does not apply

  • 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 23.

Referring to this object

Citation block

Copy this reference into your advice, article or file. The identifier, the version and the hash keep the statement findable later, even once the dataset has moved on.

Reference

Praxikon, "Article 23: obligations of importers",
praxikon:eu:ai-act:obligation:article-23-importer-obligations@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0),
effective_at 2026-08-08T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 1a3e0958b87d5b96c66eb024898d343fb1a7f570e3fcffbfe56521278f17b278,
https://www.praxikon.com/en/verkenner/obligation/article-23-importer-obligations
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-23-importer-obligations&effective_at=2026-08-08&known_at=2026-08-08&lang=en, accessed 2026-08-25)

Short form

praxikon:eu:ai-act:obligation:article-23-importer-obligations@1.0.0 (sha256 1a3e0958)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-23-importer-obligations-1-0-0,
  author       = {{Praxikon}},
  title        = {Article 23: obligations of importers},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-23-importer-obligations},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.1.0, schema 1.4.0},
  note         = {effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 1a3e0958b87d5b96c66eb024898d343fb1a7f570e3fcffbfe56521278f17b278},
  url          = {https://www.praxikon.com/en/verkenner/obligation/article-23-importer-obligations},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:article-23-importer-obligations@1.0.0",
    "type": "dataset",
    "title": "Article 23: obligations of importers",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-23-importer-obligations",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/article-23-importer-obligations",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          8
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          8,
          25
        ]
      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0; schema 1.4.0; effective_at 2026-08-08T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 1a3e0958b87d5b96c66eb024898d343fb1a7f570e3fcffbfe56521278f17b278; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-23-importer-obligations&effective_at=2026-08-08&known_at=2026-08-08&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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