Article 54: GPAI Authorised Representative
Article 54 requires non-EU providers of general-purpose AI models to appoint, by written mandate, an authorised representative established in the EU before placing the model on the market. The representative verifies compliance with Article 53, keeps a ten-year archive of the technical documentation, and cooperates with the AI Office. Open-source providers are exempt from this duty unless the model is classified as systemic risk.
- 02 Aug 2025 In force since
- 02 Aug 2026 Full enforcement powers apply
- Appoint an EU-established authorised representative by written mandate before placing a GPAI model on the EU market, if not established in the EU (Art. 54(1)).
- Ensure the representative verifies that technical documentation and Article 53 obligations are fulfilled, keeps a ten-year archive of the technical documentation, and provides compliance evidence to the AI Office on request (Art. 54(2)-(3)).
- Apply the open-source exemption from this duty only where the model is freely licensed and is not classified as posing systemic risk.
- Be aware the representative can terminate the mandate if it believes the provider is in breach, and must inform the AI Office without delay with reasons.
- Written mandate
- Ten-year archive of technical documentation held by the representative
The GPAI authorised representative under Article 54 is often confused with the high-risk system representative under Article 22; a single company can need both roles filled separately, with different mandates and different documentation obligations.
Unsettled: The exact paragraph numbering of the open-source exemption from the representative duty was not confirmed with precise sub-paragraph citations in the underlying research; check against the EUR-Lex original before citing a specific sub-provision.
What regulators published on Art. 54
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- Regulation (EU) 2024/1689 on EUR-Lex
- Look for Article 54
- Deadline changes and the acts behind them
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Get free accessInformational content only. Not legal advice and not a substitute for qualified counsel. Dates reflect Regulation (EU) 2026/1744 as of 04 Aug 2026.