In short. AI Act Article 54 requires qualifying model providers outside the Union to appoint an EU representative under a written mandate covering specified compliance tasks.

Definition: Article 54 of Regulation (EU) 2024/1689 requires providers established outside the European Union to appoint an EU-established authorised representative before placing a general-purpose AI model on the Union market, subject to an open-source exemption. An authorised representative accepts a provider's written mandate to perform specified compliance tasks on its behalf.

Key facts

As of 17 October 2026, Article 54(1) of the AI Act requires appointment by written mandate before the model enters the Union market.
The European Commission's guidelines on general-purpose AI model obligations identify an exemption for qualifying free and open-source models, unless the model presents systemic risk.
The Commission's questions and answers on general-purpose AI models state that provider obligations apply from 2 August 2025, with special rules for models already on the market.

Which providers must appoint a representative?

Under Article 3 of the AI Act, a general-purpose AI model can competently perform a wide range of distinct tasks and can be integrated into different downstream systems or applications. A provider develops a model, or has it developed, and places it on the market under its own name or trademark, whether for payment or free of charge.

Article 54 concerns providers established in third countries, meaning countries outside the Union. Their representative must be established in the Union. Article 3(5) defines the representative as a natural or legal person that receives and accepts a written mandate.

The legal provision can be located precisely as follows:

Regulation (EU) 2024/1689
Article 54
Authorised representatives of providers of general-purpose AI models

What must the written mandate cover?

Article 54(3) requires the representative to verify that the provider has prepared the technical documentation specified in Annex XI and fulfilled Article 53 obligations, plus Article 55 obligations where applicable. Article 55 concerns models with systemic risk, meaning risks that can spread at scale across the Union through a model's capabilities and use.

The representative keeps a copy of that technical documentation available to the AI Office and national competent authorities for 10 years after market placement, along with the provider's contact details. The AI Office is the European Commission's function for implementing, monitoring and supervising AI systems and general-purpose AI models.

The mandate also covers supplying compliance information to the AI Office and cooperating with it and competent authorities upon reasoned requests. The representative must supply a copy of the mandate to the AI Office on request, in an official Union language. The provider must enable the representative to perform its tasks.

Paragraph 4 empowers authorities to address the representative alongside or instead of the provider. Under paragraph 5, the representative must terminate its mandate if it considers, or has reason to consider, that the provider acts contrary to its obligations, and immediately inform the AI Office of the termination and reasons.

How does the open-source exemption affect website publishers?

Article 54(6) requires a free and open-source licence allowing access, use, modification and distribution, together with public availability of model parameters, including weights, architecture information and usage information. The exemption excludes models presenting systemic risks.

For publishers concerned about training on web content, Article 53(1)(c) requires a provider copyright policy, including identifying and respecting qualifying reservations of rights. Article 53(1)(d) requires a public training-content summary. The open-source exemptions in Article 53(2) cover documentation duties; these copyright and summary duties remain applicable. Article 54(3)(a) connects the representative's verification task to those provider obligations.

FAQ

Does an older model have a different compliance deadline?

Yes. Article 111(3) gives providers of general-purpose AI models placed on the market before 2 August 2025 until 2 August 2027 to comply with the regulation's obligations.

Does Article 54 give website owners access to the technical documentation?

Article 54(3)(b) requires the representative to keep technical documentation available to the AI Office and national competent authorities. The separate public disclosure relevant to training content is the summary required by Article 53(1)(d).

Sources

Check how a page reads to answer engines. Open the GEO score analyzer