Art. 54: Authorised representatives of providers of general-purpose AI models under the EU AI Act

Art. 54 requires a provider of a general-purpose AI model established in a third country to appoint, by written mandate, an authorised representative established in the Union before it places the model on the Union market. The representative verifies the Annex XI documentation, keeps a copy for the AI Office, answers reasoned requests and terminates the mandate where the provider acts contrary to its obligations. In this mapping two elements are testable, four are documentation and six are process. Regulation (EU) 2026/1744 did not move the GPAI application date 2025-08-02In force.

Where this applies

2025-08-02In forceGPAI obligations, Art. 53-55
2026-08-02In forceCommission enforcement powers for GPAI (fines, requests for information)

What the text requires

The exception in Art. 54(6) rests on the licence terms, the public availability of the parameters with the weights, the architecture information and the usage information, and the absence of systemic risk under Art. 51. The Commission guidelines on GPAI scope supply the criteria for each condition. A provider that claims the exception keeps a record for every condition, listed in the documentation row below.

What the text requires and how each element is verified
Requires	Testable	Documentation	Process
Art. 54(1)A provider established in a third country appoints an authorised representative established in the Union. The appointment is made by written mandate. The appointment is made before the provider places the general-purpose AI model on the Union market. Art. 54(2)The provider enables its authorised representative to perform the tasks specified in the mandate received from the provider. Art. 54(3)The authorised representative performs the tasks specified in the mandate. The representative provides a copy of the mandate to the AI Office on request. The copy is in one of the official languages of the institutions of the Union. The mandate empowers the representative to carry out the tasks in points (a) to (d). Art. 54(3)(a)The representative verifies that the technical documentation specified in Annex XI has been drawn up. The representative verifies that all obligations referred to in Art. 53 and, where applicable, Art. 55 have been fulfilled by the provider. Art. 54(3)(b)The representative keeps a copy of the technical documentation specified in Annex XI at the disposal of the AI Office and national competent authorities. The representative keeps the contact details of the provider that appointed it. The retention period is 10 years after the general-purpose AI model has been placed on the market. Art. 54(3)(c)On a reasoned request, the representative provides the AI Office with all the information and documentation, including the documentation in point (b), that is necessary to show that the obligations in Chapter V are fulfilled. Art. 54(3)(d)On a reasoned request, the representative cooperates with the AI Office and competent authorities in any action they take in relation to the general-purpose AI model. This includes the case where the model is integrated into AI systems placed on the market or put into service in the Union. Art. 54(4)The mandate empowers the representative to be addressed by the AI Office or the competent authorities, in addition to or instead of the provider, on all issues that relate to the provider's obligations under this Regulation. Art. 54(5)The representative terminates the mandate if it considers, or has reason to consider, that the provider acts contrary to its obligations under this Regulation. In that case the representative immediately informs the AI Office about the termination and the reasons for it. Art. 54(6)The obligation in this Article does not apply to a provider of a general-purpose AI model released under a free and open-source licence that allows access, usage, modification and distribution of the model, where the parameters, including the weights, the information on the model architecture and the information on model usage, are made publicly available. The exception does not apply where the general-purpose AI model presents systemic risk.	Mandate verification: the written mandate exists, appoints a representative established in the Union, carries a date earlier than the placing of the model on the Union market, lists each task in Art. 54(3)(a) to (d) and the power in Art. 54(4), and a copy in one of the official languages of the institutions of the Union is produced on request (Art. 54(1), (3) and (4)) Retrieval exercise: on a simulated reasoned request, the representative produces from its own custody the current Annex XI technical documentation copy, the provider's contact details and the information that shows the Chapter V obligations are fulfilled (Art. 54(3)(b) and (c))	Mandate copy held by the representative in one of the official languages of the institutions of the Union, ready for the AI Office (Art. 54(3)) Copy of the Annex XI technical documentation held by the representative, at the version the provider maintains (Art. 54(3)(b)) Record of the provider's contact details held by the representative (Art. 54(3)(b)) Applicability record: the provider's place of establishment, the placing of the model on the Union market, and, where the exception is claimed, evidence for each Art. 54(6) condition, namely the licence terms, the public availability of the parameters, the weights, the model architecture information and the model usage information, and the absence of a systemic-risk classification under Art. 51	The provider enables the representative to perform the mandate tasks: access to the Annex XI documentation, a channel for documentation updates, and a contact path to the provider (Art. 54(2)) The representative verifies that the Annex XI documentation has been drawn up and that the Art. 53 and, where applicable, Art. 55 obligations have been fulfilled, before placing on the market and again on each documentation change (Art. 54(3)(a)) The representative retains the Annex XI copy and the provider's contact details for the period in Art. 54(3)(b), with the copy updated when the provider updates the documentation The representative handles reasoned requests from the AI Office and competent authorities: it provides information and documentation and it cooperates in any action on the model, including where the model is integrated into AI systems in the Union (Art. 54(3)(c) and (d)) The representative is reachable by the AI Office and competent authorities in addition to or instead of the provider on all issues that relate to the provider's obligations (Art. 54(4)) The representative monitors for reason to consider that the provider acts contrary to its obligations, terminates the mandate where that is the case, and immediately informs the AI Office with the reasons (Art. 54(5))

Metrics and where thresholds come from

Threshold sources, in order of precedence

A harmonised standard cited in the Official Journal (none as of the anchor date)
A JTC 21 draft standard (prEN), with its stage
An ISO/IEC standard or technical report, with its stage
A Commission guideline or code of practice, with its date from the standards data
NIST AI RMF or a sector framework
The state of the art, which the provider justifies and documents

Regulation (EU) 2024/1689 sets no numeric test threshold for Art. 54. The one figure in the article is the retention period in Art. 54(3)(b), a duration counted from the placing of the model on the market, not a performance threshold. No harmonised standard covers Art. 54, and no harmonised standard is cited in the Official Journal as of the anchor date. The hierarchy level in use today is the Commission guideline and Code of Practice level: the Commission guidelines on GPAI scope for applicability and the exception, and the GPAI Code of Practice for the documentation set. The provider justifies and documents any acceptance criterion it sets for the mandate check and the retrieval exercise, such as a retrieval time target, against the context of use; the PR-CLS determination-rationale step records the justification.

Metric sources and their stage
Source and stage	Title	What it provides here	Verified on
`Commission guidelines on GPAI scope`Published	Guidelines on the scope of obligations for providers of general-purpose AI models under the AI Act	criteria for whether the model is a general-purpose AI model, whether a third-country entity is its provider after modification, whether the model is placed on the Union market, and whether the licence, no-monetisation and public-availability conditions behind the Art. 54(6) exception are met	Verified on 18 September 2026European Commission, Guidelines on the scope of obligations for providers of general-purpose AI models
`GPAI Code of Practice`Published	General-Purpose AI Code of Practice (transparency, copyright, safety and security chapters)	the Model Documentation Form and the transparency chapter, which define the documentation set the representative verifies under Art. 54(3)(a), keeps under Art. 54(3)(b) and produces under Art. 54(3)(c)	Verified on 18 September 2026European Commission, The General-Purpose AI Code of Practice

Procedures

Each protocol is versioned; its page states the derivation from the standards above. PR-CLS v1.0 records the applicability determination, the exception check and the acceptance criterion for the mandate check and the retrieval exercise.

PR-CLS v1.0Classification and role determination protocolv1.0

What an assessor asks for

Authorised representative written mandate (Art. 54(1))
Mandate copy in an official language of the institutions of the Union (Art. 54(3))
Annex XI technical documentation copy held by the representative (Art. 54(3)(b))
Provider contact details record (Art. 54(3)(b))
Representative verification record of Annex XI documentation and Art. 53 and 55 fulfilment (Art. 54(3)(a))
Reasoned-request handling procedure (Art. 54(3)(c) and (d))
Mandate termination and AI Office notification procedure (Art. 54(5))
Article 54 applicability and exception determination memo (PR-CLS output)

Common findings

The mandate names the representative but does not list the tasks in Art. 54(3)(a) to (d) or the power in Art. 54(4)
The representative holds a link to the provider's documentation repository rather than its own copy of the Annex XI technical documentation
The Annex XI copy held by the representative is an earlier version than the documentation the provider maintains
The mandate carries a date later than the first availability of the model in the Union
The open-source exception is claimed on the licence text alone, without a record that the weights, the architecture information and the usage information are publicly available or that the model is not classified as presenting systemic risk
No trigger and no procedure exist for the termination duty in Art. 54(5)

Questions

What does AI Act Article 54 require?

Art. 54(1) requires a provider of a general-purpose AI model established in a third country to appoint an authorised representative established in the Union by written mandate before placing the model on the Union market. Art. 54(2) requires the provider to enable the representative to perform the mandate tasks. Art. 54(3) requires the representative to verify the Annex XI documentation and the Art. 53 and Art. 55 obligations, to keep a copy of the documentation and the provider's contact details, to provide information to the AI Office on reasoned request, and to cooperate with the AI Office and competent authorities. Art. 54(4) allows the AI Office and competent authorities to address the representative instead of the provider. Art. 54(5) requires the representative to terminate the mandate and inform the AI Office where it has reason to consider that the provider acts contrary to its obligations. Art. 54(6) exempts providers of free and open-source models with publicly available parameters, unless the model presents systemic risk. The Commission guidelines on GPAI scope set the criteria for the exception.

What does Article 54 on authorised representatives of providers of general-purpose AI models cover?

Article 54 applies to providers of general-purpose AI models established outside the Union (Art. 54(1)). The representative is a natural or legal person established in the Union that holds a written mandate from the provider (Art. 3(5) and Art. 54(1)). The mandate lists the tasks in Art. 54(3)(a) to (d) and the power in Art. 54(4). The representative keeps a copy of the Annex XI technical documentation for the retention period in Art. 54(3)(b). The representative provides the mandate copy to the AI Office on request in one of the official languages of the institutions of the Union (Art. 54(3)). The exception in Art. 54(6) covers free and open-source models with publicly available parameters and does not cover models with systemic risk. The applicability dates come from the gpai-obligations and gpai-commission-enforcement entries on the regulation page.

How we test this

We verify the written mandate against Art. 54(1), (3) and (4) and we run the retrieval exercise in which the representative produces the Annex XI copy, the provider's contact details and the Chapter V evidence from its own custody. We document the applicability and exception determination through PR-CLS v1.0; the service scope excludes a legal opinion on the provider's place of establishment.

Classification and readiness assessmentPR-CLS
GPAI evaluation supportPR-15-ROB, PR-CLS, PR-11-DOC

What we cannot do

We do not perform conformity assessments where a notified body is required.
We do not issue CE marking or the EU Declaration of Conformity.
We are not a notified body.
We do not give legal opinions on classification or liability.
We test against requirements, prepare evidence, and structure documentation; compliance decisions remain with the provider or deployer, their notified body, and their counsel.

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