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ObligationApplicablev1.0.0

Article 54: 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 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-54-gpai-authorised-representative
Payload hash (sha256)
0c470c29e8f0c2ad222dc0517b6a9437615474bfc6429e9c37b90eb35572d5c5

Citation line

Praxikon, "Article 54: authorised representative of a provider of a GPAI model", praxikon:eu:ai-act:obligation:article-54-gpai-authorised-representative@1.0.0, dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0), effective_at 2026-08-08T00:00:00.000Z, known_at 2026-09-06T00:00:00.000Z, sha256 0c470c29e8f0c2ad222dc0517b6a9437615474bfc6429e9c37b90eb35572d5c5
Version
1.0.0
Legal time (effective_at)
2 August 2025
Knowledge time (known_at)
14 August 2026
Closed on
Not closed
Application date
2 August 2025
Topics
gpai, value-chain

Review status: Placed against the official source (14 August 2026). Next check due by 10 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

Affected actor

Not recorded on this object.

Oversight

Evidence owner

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

2 of 2 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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

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

    Consequence

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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

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

    Consequence

    • ActorAI Office

      praxikon:eu:ai-act:actor:ai-office

Who owns the evidence

2 of 2 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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

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

    Consequence

The obligation this hangs off

2 of 2 shown

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

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

    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 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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allApplies 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.
    • Condition | any ofFor 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.
    • ExceptionParagraph 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.

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    • Condition | allTo be carried out before the model is placed on the Union market, and to be revisited on every change to the model, to the provider establishment or to the licence under which the model is released. For models placed on the market before 2 August 2025, the Article 111(3) period runs until 2 August 2027.

    Relation recorded on: Appoint an authorised representative and record the mandate

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Periodic review and termination of the mandate

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

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

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Mandate file of the authorised representative

    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 54(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 3(5)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 113(3)(b)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 101(1)-(6)

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

      Open official source

    • EU Artificial Intelligence Act 2024/1689

      Locator: Article 111(3)

      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 54

    Consequence

What this object states

Official fact

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

  • Paragraph 1 provides that, prior to placing a general-purpose AI model on the Union market, providers established in third countries shall, by written mandate, appoint an authorised representative which is established in the Union. Paragraph 2 provides that the provider shall enable its authorised representative to perform the tasks specified in the mandate received from the provider. Paragraph 3 provides that the authorised representative shall perform the tasks specified in the mandate received from the provider, that it shall provide a copy of the mandate to the AI Office upon request in one of the official languages of the institutions of the Union, and that for the purposes of the Regulation the mandate shall empower the authorised representative to carry out the following tasks: (a) verify that the technical documentation specified in Annex XI has been drawn up and all obligations referred to in Article 53 and, where applicable, Article 55 have been fulfilled by the provider; (b) keep a copy of the technical documentation specified in Annex XI at the disposal of the AI Office and national competent authorities, for a period of 10 years after the general-purpose AI model has been placed on the market, and the contact details of the provider that appointed the authorised representative; (c) provide the AI Office, upon a reasoned request, with all the information and documentation, including that referred to in point (b), necessary to demonstrate compliance with the obligations in that Chapter; (d) cooperate with the AI Office and competent authorities, upon a reasoned request, in any action they take in relation to the general-purpose AI model, including when the model is integrated into AI systems placed on the market or put into service in the Union. Paragraph 4 provides that the mandate shall empower the authorised representative to be addressed, in addition to or instead of the provider, by the AI Office or the competent authorities, on all issues related to ensuring compliance with the Regulation. Paragraph 5 provides that the authorised representative shall terminate the mandate if it considers or has reason to consider the provider to be acting contrary to its obligations pursuant to the Regulation, and that in such a case it shall also immediately inform the AI Office about the termination of the mandate and the reasons therefor. Paragraph 6 provides that the obligation set out in that Article shall not apply to providers of general-purpose AI models that are released under a free and open-source licence that allows for the access, usage, modification, and distribution of the model, and whose parameters, including the weights, the information on the model architecture, and the information on model usage, are made publicly available, unless the general-purpose AI models present systemic risks.

  • Article 113(3)(b) provides that Chapter III Section 4, Chapter V, Chapter VII and Chapter XII and Article 78 shall apply from 2 August 2025, with the exception of Article 101. Article 54 sits in Chapter V and therefore applies from 2 August 2025.

  • Article 101(1) provides that the Commission may impose on providers of general-purpose AI models fines not exceeding 3 percent of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000, whichever is higher. Article 101 is excluded by Article 113(3)(b) from the earlier application of Chapter XII and has therefore applied since 2 August 2026. The obligation in Article 54 has thus applied since 2 August 2025, while the Commission fining power behind it exists only since 2 August 2026.

  • Providers of general-purpose AI models that have been placed on the market before 2 August 2025 shall take the necessary steps in order to comply with the obligations laid down in the Regulation by 2 August 2027.

Our interpretation

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

  • This article touches two parties that rarely see themselves that way. The first is the model provider outside the Union that assumes nothing is required until a European customer asks: paragraph 1 places the appointment before the placing on the market, so the representative should exist before the first user in the Union can access the model. The second is the European party that accepts the mandate. It is not stepping into a mailbox role, but note how paragraph 3 is built: the first sentence obliges it to perform the tasks the mandate assigns to it, and only then does the article list what the mandate empowers it to do. Points (a) to (d) are therefore mandate content and empowerment, and its duty runs through them. That is where this article leaves its sharpest question open: is a representative that accepts a mandate omitting task (a) or (b) itself in breach, or does the failure rest entirely with the provider that drew up the mandate. We read paragraph 3 as making the list mandatory minimum content, so that a mandate lacking it does not satisfy the article, which leaves the provider answerable under paragraph 1 and the representative answerable for what it did accept. A defensible alternative reading is that a representative signing without those powers takes on a task it cannot discharge and thereby falls short itself. So do not assume the ten year retention in point (b) rests on you automatically, or automatically does not; write it out. Paragraph 5 closes this off in a way that is often missed: a representative that considers, or has reason to consider, that the provider is breaching its obligations terminates the mandate and immediately informs the AI Office. That is a duty rather than a power, and it calls for access to the documentation agreed in advance and for a moment at which that access is tested.

  • Three things about the timeline and the scope. First, the difference between duty and enforcement: the duty has applied since 2 August 2025, but Article 101 is excluded from the earlier application, so the Commission can only fine since 2 August 2026. For a provider outside the Union discovering today that it has no representative, that means: in breach for well over a year, and now also exposed to a fine. Second, the relationship with Article 22. That article carries the same figure for high-risk AI systems, starting on 2 December 2027 and 2 August 2028; Article 54 is the separate route for general-purpose AI models and has applied since 2 August 2025. Anyone looking up the role of authorised representative finds both and needs to know which route applies. Third, the trigger in paragraph 1. The Regulation fixes the moment of placing on the market less sharply for a model than for a system, and for a model made available only through an interface from a third country there is no case law. We read the duty as starting once the model is made available to users in the Union in the course of a commercial activity, because paragraph 1 attaches to placing on the market and not to establishment in the Union. A defensible alternative reading is that making a model available through an interface is not placing the model itself on the market, so that the duty only arises on an actual supply of the model.

    • Locator: Article 54(1)-(6)praxikon:eu:ai-act:source:reg-eu-2024-1689Open official source
    • Locator: Article 113(3)(b)praxikon:eu:ai-act:source:reg-eu-2024-1689Open official source
    • Locator: Article 1, point (40)(b) and (c), replacing Article 113, third paragraph, point (c) and adding point (d)praxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

Recommended step

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

  • First establish whether you are the provider of the model or only a user, because only the provider appoints. If you are established outside the Union, put the mandate in writing before the model becomes available here, and write the four tasks in paragraph 3 into it expressly, together with the access to the Annex XI documentation and the point of contact under paragraph 4. If your model was already on the market before 2 August 2025, work to 2 August 2027 rather than to today. If you are only now discovering that there is no representative, assume the duty has run since 2 August 2025 and that the Commission has been able to fine since 2 August 2026; remedy first and record when you did. If you accept a mandate, agree in advance how you carry out the verification in paragraph 3(a), who holds the copy for ten years, and at what moment you test whether termination under paragraph 5 is called for.

When this applies

  1. 1Applies 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.
  2. 2For 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.

When this does not apply

  • 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.

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 54: authorised representative of a provider of a GPAI model",
praxikon:eu:ai-act:obligation:article-54-gpai-authorised-representative@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0 (schema 1.5.0),
effective_at 2025-08-02T00:00:00.000Z, known_at 2026-08-14T00:00:00.000Z,
sha256 0c470c29e8f0c2ad222dc0517b6a9437615474bfc6429e9c37b90eb35572d5c5,
https://www.praxikon.com/en/verkenner/obligation/article-54-gpai-authorised-representative
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-54-gpai-authorised-representative&effective_at=2025-08-02&known_at=2026-08-14&lang=en, accessed 2026-09-20)

Short form

praxikon:eu:ai-act:obligation:article-54-gpai-authorised-representative@1.0.0 (sha256 0c470c29)

BibTeX

@misc{praxikon-eu-ai-act-obligation-article-54-gpai-authorised-representative-1-0-0,
  author       = {{Praxikon}},
  title        = {Article 54: authorised representative of a provider of a GPAI model},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:article-54-gpai-authorised-representative},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.2.0, schema 1.5.0},
  note         = {effective_at 2025-08-02T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 0c470c29e8f0c2ad222dc0517b6a9437615474bfc6429e9c37b90eb35572d5c5},
  url          = {https://www.praxikon.com/en/verkenner/obligation/article-54-gpai-authorised-representative},
  urldate      = {2026-09-20},
  language     = {en}
}

CSL JSON

[
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    "type": "dataset",
    "title": "Article 54: authorised representative of a provider of a GPAI model",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:article-54-gpai-authorised-representative",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/article-54-gpai-authorised-representative",
    "language": "en",
    "issued": {
      "date-parts": [
        [
          2026,
          8,
          14
        ]
      ]
    },
    "accessed": {
      "date-parts": [
        [
          2026,
          9,
          20
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      ]
    },
    "note": "dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.2.0; schema 1.5.0; effective_at 2025-08-02T00:00:00.000Z; known_at 2026-08-14T00:00:00.000Z; sha256 0c470c29e8f0c2ad222dc0517b6a9437615474bfc6429e9c37b90eb35572d5c5; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Aarticle-54-gpai-authorised-representative&effective_at=2025-08-02&known_at=2026-08-14&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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