Article 54: Appointing Representatives for AI Models in the EU

Introduction

Starting 2 August 2025, Article 54 of the EU AI Act introduces mandatory requirements for providers of general-purpose AI models established outside the European Union. This regulation requires these providers to appoint an Authorised Representative within the EU before placing their AI models on the market.

What is an Authorised Representative?

An Authorised Representative is a legally appointed entity within the EU, tasked with ensuring compliance with EU regulations on behalf of providers based outside the Union. They act as the crucial link between the provider and regulatory authorities.

Key responsibilities under Article 54 include:

• Verifying Compliance: Ensuring technical documentation (as specified in Annex XI) is correctly prepared and that providers meet all related obligations.

• Documentation Maintenance: Maintaining technical documentation to ensure it remains accessible to the EU AI Office and national authorities for a minimum of 10 years.

• Information Provision: Supplying required documentation and information upon official request.

• Cooperation: Collaborating fully with the EU AI Office and national authorities on any compliance issues or investigations.

Who Needs to Comply?

Providers established outside the EU offering general-purpose AI models to the EU market must comply with Article 54.

However, exceptions apply to open-source models. Models released under free, open-source licenses, with publicly available parameters and architecture details, do not need an authorised representative unless they present systemic risks.

Steps for Compliance

To ensure compliance, providers must:

1. Appoint an Authorised Representative: Issue a written mandate to an EU-based representative, clearly defining their responsibilities.

2. Prepare Technical Documentation: Compile comprehensive documentation as required by Annex XI, maintaining availability for a minimum of 10 years.

3. Establish Clear Communication: Ensure seamless communication channels with the representative for regulatory interactions and documentation requests.

How GDPR Local Can Help

At GDPR Local, we simplify your compliance journey:

• Appointment Assistance: Identify and appoint reliable Authorised Representatives tailored to your business.

• Documentation and Compliance Support: Guide you in preparing and managing compliant technical documentation.

• Continuous Management: Provide ongoing compliance monitoring and audit preparedness to ensure smooth regulatory interactions.

Conclusion

Early and thorough preparation is key to seamless compliance with Article 54. Taking action now ensures your AI innovations can smoothly enter and thrive in the EU market. Contact GDPR Local today and ensure your AI models are compliance-ready!