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Chapter V — General-purpose AI modelsArticle 54

Article 54: Authorised Representatives of Providers of GPAI Models

In effect since 2 Aug 20254 min readEUR-Lex verified Apr 2026

Article 54 requires providers of general-purpose AI (GPAI) models established in third countries (outside the EU) to appoint an authorised representative established in the Union before making the model available on the Union market. The representative must have a written mandate granting authority to carry out specified tasks on behalf of the provider, including: keeping the technical documentation and downstream transparency information available, cooperating with the AI Office and national authorities, and handling information requests. The representative must be able to demonstrate compliance with Chapter V obligations upon request.

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Who does this apply to?

  • -Third-country providers of GPAI models placing them on the EU market
  • -EU-based entities acting as authorised representatives
  • -The AI Office which interacts with representatives for enforcement
  • -Downstream providers integrating GPAI models who must identify the responsible entity

Scenarios

A US-based AI company offers its large language model via API to EU businesses. It appoints a Berlin-based compliance firm as authorised representative.

The Berlin firm receives a written mandate, keeps Annex XI/XII documentation, and serves as the AI Office's contact point.
Ref. Art. 54

A Chinese AI lab releases an open-weight model widely adopted in the EU but has no EU entity or representative.

Non-compliant with Article 54 — the model cannot lawfully be made available on the Union market without a representative.
Ref. Art. 54

A third-country GPAI provider with systemic risk classification appoints a representative. The AI Office requests adversarial testing results.

The representative must be able to facilitate the request and demonstrate Article 55 compliance on behalf of the provider.
Ref. Art. 54 + Art. 55

When an authorised representative is required

The rule is straightforward: if the GPAI model provider is established outside the Union, it must appoint an authorised representative before making the model available on the Union market.

This mirrors the approach in EU product-safety law (e.g., MDR, Machinery Regulation) adapted for GPAI models. Unlike the high-risk AI system representative under Article 22 (which covers physical products), Article 54 is specific to GPAI models and their relationship with the AI Office rather than Member State market surveillance.

What the mandate must cover

The written mandate must grant the representative authority to:

1. Keep Annex XI technical documentation available for 10 years after market availability 2. Keep Annex XII downstream transparency information available 3. Cooperate with the AI Office and national competent authorities on information requests 4. Provide on request the information necessary to demonstrate compliance with Chapter V 5. Terminate the mandate if the provider acts contrary to its obligations (the representative must inform the AI Office)

The provider remains fully responsible — appointing a representative does not transfer liability.

How Article 54 connects to the rest of the Act

  • Article 53 — Core GPAI model obligations the representative helps enforce.
  • Article 55 — Additional systemic risk obligations the representative may need to facilitate.
  • Annex XI — Technical documentation the representative must keep available.
  • Annex XII — Downstream transparency information.
  • Article 101 — GPAI fines (AI Office enforced).
  • Article 22 — Separate authorised representative for high-risk AI *systems* (different scope).

Compliance checklist

  • Determine if the GPAI model provider is established outside the Union.
  • Appoint an authorised representative established in the Union with a written mandate.
  • Ensure the mandate covers Annex XI/XII documentation, AI Office cooperation, and compliance demonstration.
  • Include mandate termination clause if the provider acts contrary to Chapter V.
  • Inform the AI Office of the representative's identity and contact details.
  • Maintain documentation that the representative can access and present on request.
  • Distinguish Article 54 (GPAI representative) from Article 22 (high-risk system representative).
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Related annexes

  • Annex XI — Technical documentation for GPAI models
  • Annex XII — Transparency information for GPAI models

Frequently asked questions

Is Article 54 the same as the high-risk system authorised representative?

No. Article 54 covers GPAI model providers and interacts with the AI Office. Article 22 covers high-risk AI system providers and interacts with national market surveillance. Different scope, different authority.

Can the representative also be the importer?

The AI Act does not prohibit this, but the roles have different obligations. Ensure each set of duties is contractually addressed.

What happens if the representative terminates the mandate?

The representative must inform the AI Office. The provider must appoint a new representative before continuing to make the model available in the Union.