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ObligationUpcomingv1.0.0

Articles 22-25: value chain and authorised representative

Role shifts in the AI value chain and the mandatory representative for non-EU providers.

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:value-chain-representative
Payload hash (sha256)
38342a3db27dd0959f29e10415d9217331e2056d163b17a95fef284213092d52

Citation line

Praxikon, "Articles 22-25: value chain and authorised representative", praxikon:eu:ai-act:obligation:value-chain-representative@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 38342a3db27dd0959f29e10415d9217331e2056d163b17a95fef284213092d52
Version
1.0.0
Legal time (effective_at)
27 July 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

Affected actor

  • Deployerpraxikon:eu:ai-act:actor:deployer

Oversight

Not recorded on this object.

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

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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

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

    Consequence

Who is affected without being the addressee

1 of 1 shown

This role is practically affected without being the addressee: it receives the information, has to cooperate, or absorbs the consequences in its own process.

  1. Source

    Official fact on this object, with its locator.

    • EU Artificial Intelligence Act 2024/1689

      Locator: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

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

    Consequence

    • ActorDeployer

      praxikon:eu:ai-act:actor:deployer

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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

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

    Consequence

    • EvidenceValue-chain file

      praxikon:eu:ai-act:evidence:value-chain-representative-record

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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    • Condition | allA high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
    • ExceptionThose acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Assess the value-chain role per system and change

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Role reassessment on every change

    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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Value-chain file

    Consequence

    • EvidenceValue-chain file

      praxikon:eu:ai-act:evidence:value-chain-representative-record

  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: Articles 22 and 25

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

      Open official source

    • Digital Omnibus on AI 2026/1744

      Locator: Amended Article 113 application dates

      praxikon:eu:ai-act:source:reg-eu-2026-1744

      Open official source

    Via

    No condition or exception recorded on this object.

    Relation recorded on: Full text of Article 25

    Consequence

What this object states

Official fact

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

  • Article 25 provides that a distributor, importer, deployer or third party becomes the provider when it puts its name on a high-risk system, substantially modifies it or changes its intended purpose so it becomes high-risk; Article 22 obliges third-country providers to appoint a written authorised representative in the Union.

  • For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.

    • Locator: Amended Article 113 application datespraxikon:eu:ai-act:source:reg-eu-2026-1744Open official source

Our interpretation

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

  • The most dangerous role switch is the unintended one: your own layer on top of a procured model, your own brand on a tool, and you suddenly carry the full provider duties. This belongs as a standing question in every AI project.

Recommended step

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

  • Include the role question in the AI register and in project gates, and contractually define who supplies which information and cooperation on changes.

When this applies

  1. 1A high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.

When this does not apply

  • Those acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.

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, "Articles 22-25: value chain and authorised representative",
praxikon:eu:ai-act:obligation:value-chain-representative@1.0.0,
dataset praxikon:sys:registry:dataset:ai-act-implementation-graph 2.1.0 (schema 1.4.0),
effective_at 2026-07-27T00:00:00.000Z, known_at 2026-08-08T00:00:00.000Z,
sha256 38342a3db27dd0959f29e10415d9217331e2056d163b17a95fef284213092d52,
https://www.praxikon.com/en/verkenner/obligation/value-chain-representative
(https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Avalue-chain-representative&effective_at=2026-07-27&known_at=2026-08-08&lang=en, accessed 2026-08-25)

Short form

praxikon:eu:ai-act:obligation:value-chain-representative@1.0.0 (sha256 38342a3d)

BibTeX

@misc{praxikon-eu-ai-act-obligation-value-chain-representative-1-0-0,
  author       = {{Praxikon}},
  title        = {Articles 22-25: value chain and authorised representative},
  year         = {2026},
  version      = {1.0.0},
  number       = {praxikon:eu:ai-act:obligation:value-chain-representative},
  howpublished = {AI Act Change \& Evidence Graph, dataset 2.1.0, schema 1.4.0},
  note         = {effective_at 2026-07-27T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 38342a3db27dd0959f29e10415d9217331e2056d163b17a95fef284213092d52},
  url          = {https://www.praxikon.com/en/verkenner/obligation/value-chain-representative},
  urldate      = {2026-08-25},
  language     = {en}
}

CSL JSON

[
  {
    "id": "praxikon:eu:ai-act:obligation:value-chain-representative@1.0.0",
    "type": "dataset",
    "title": "Articles 22-25: value chain and authorised representative",
    "container-title": "AI Act Change & Evidence Graph",
    "publisher": "Praxikon",
    "version": "1.0.0",
    "number": "praxikon:eu:ai-act:obligation:value-chain-representative",
    "URL": "https://www.praxikon.com/en/verkenner/obligation/value-chain-representative",
    "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 2026-07-27T00:00:00.000Z; known_at 2026-08-08T00:00:00.000Z; sha256 38342a3db27dd0959f29e10415d9217331e2056d163b17a95fef284213092d52; retrieved_from https://www.praxikon.com/api/v1/obligations?id=praxikon%3Aeu%3Aai-act%3Aobligation%3Avalue-chain-representative&effective_at=2026-07-27&known_at=2026-08-08&lang=en; licence https://www.praxikon.com/nl/legal/terms"
  }
]

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