Articles 22 & 54
When does a U.S. AI provider need an EU Authorised Representative?
The EU AI Act contains separate representative regimes for non-EU providers of high-risk AI systems and non-EU providers of general-purpose AI models. Not every U.S. company in scope needs an authorised representative.
Updated and legally reviewed: 27 September 2026 · Reviewed by Constantin Razvan Gospodin.
Short answer
Not every U.S. company needs an EU authorised representative.
The requirement is role-specific. It is most relevant to third-country providers of high-risk AI systems under Article 22 and third-country providers of GPAI models under Article 54. A deployer or ordinary customer should not appoint a representative merely because it uses AI in Europe.
Article 22
Non-EU providers of high-risk AI systems
Before making a high-risk AI system available on the Union market, a provider established in a third country must appoint, by written mandate, an authorised representative established in the Union.
Verify compliance documents
The mandate must empower the representative to verify that required conformity documentation and procedures have been completed.
Maintain records
Specified provider/contact, declaration, technical documentation and certificate records must be kept available to authorities for the required period.
Respond to authorities
Provide information/documentation on reasoned request and cooperate with competent authorities, including risk-mitigation actions.
Registration support
Where applicable, the representative can carry out or verify specified registration obligations under Article 49.
Article 54
Non-EU providers of GPAI models
Before placing a GPAI model on the Union market, a third-country provider generally must appoint an EU-established authorised representative. Article 54 contains an exception for qualifying free/open-source GPAI models unless they present systemic risk.
Documentation interface
The representative supports the provider's documentation and authority-interface obligations under the GPAI chapter.
AI Office cooperation
The mandate allows the representative to provide information and cooperate with the AI Office and competent authorities on reasoned request.
Scoping
Do not appoint a representative before determining the legal role.
- Confirm the company is acting as a provider, not merely a deployer/customer.
- For an AI system, determine whether the high-risk regime is relevant.
- For a model, determine whether it is GPAI and whether an Article 54 exception applies.
- Confirm the EU-market activity triggering the representative requirement.
- Define the written mandate, records, authority interface and termination/escalation obligations.
Commercial boundary
Coordination is different from holding the statutory mandate.
EUAIACTUS.COM can support scoping, documentation readiness and representative coordination. The statutory authorised representative must itself be located or established in the Union, accept a written mandate and perform the obligations assigned by the AI Act.
Official sources
Representative provisions
Article 22 — representatives of high-risk AI providers
Legal status reviewed: 27 September 2026. Article 54 includes an exception for qualifying free/open-source GPAI models unless they present systemic risk.