EU AI Act Art. 54: authorised representative of non-EU GPAI providers

A GPAI provider established outside the Union appoints, by written mandate, an authorised representative before placing the model on the Union market; the representative keeps the Annex XI documentation for 10 years

By Jorge García Aibar Reviewed 2026-09-24

From clause to evidence Build the artefact, then file every output it produces as a record that names AIGE-OBL-EUAIA-ART54. Drawn from chapter 08.

Text alternative

Clause: EU AI Act, Art. 54.
Duty holder: Non-EU GPAI provider +….
Applies from: 2025-08-02, In force.
Artefact: Written mandate.
Layer: Layer 05 Assurance & Continuous Compliance.
Evidence record: Evidence record v1.
Record schema: Evidence record.
The same topic in 15 other frameworks; the crosswalk section below links each clause.

When this obligation applies The first date in the row's status, then each later step: filled once its date has passed, outlined while it is still ahead of the review date.

Data table: the dates

Dates of AIGE-OBL-EUAIA-ART54
Date	Step	Detail
2025-08-02	In force	Obligations from 2025-08-02; enforcement from 2026-08-02
2026-08-02	Later step	Commission enforcement powers apply
2027-08-02	Later step	GPAI models placed on the market before 2025-08-02 comply by this date (Art. 111(3))

Id

AIGE-OBL-EUAIA-ART54

Instrument

EU AI Act (post-Omnibus) law

Compared side by side

ISO 42001 vs EU AI Act · NIST AI RMF vs EU AI Act

Clause

Art. 54

Duty holder

Non-EU GPAI provider + authorised representative

Authority

AI Office

Applies from

2025-08-02 In force · Obligations from 2025-08-02; enforcement from 2026-08-02

Later dates

2026-08-02 Commission enforcement powers apply
2027-08-02 GPAI models placed on the market before 2025-08-02 comply by this date (Art. 111(3))

System class

GPAI model

The artefact that evidences it

Written mandate; Annex XI documentation copy kept 10 years; AI Office contact route.

L5 Assurance & Continuous Compliance

What this obligation connects to Solid edges are direct relations, dashed ones looser (a case that cites the same article, a framework whose clauses only touch the topic); patterns and controls take the colour of their stack layer. Select a node to open it; the lists below give every relation in full.

Data table: every relation

Relations of AIGE-OBL-EUAIA-ART54
Family	Item	Relation
Same crosswalk topic	AI Verify 9.7.1, 5.3.1, 4.5.2, 9.3.1	Core clause
Same crosswalk topic	CSA AICM STA-10, STA-09	Core clause
Same crosswalk topic	EU AI Act Art. 25, Art. 25(4), Art. 26, Art. 22, Art. 23, Art. 24	Core clause
Same crosswalk topic	GDPR Art. 28, Arts. 44–46	Core clause
Same crosswalk topic	ISO 42001 A.10	Core clause
Same crosswalk topic	NIST AI RMF GOVERN 6, MAP 4, MANAGE 3, MANAGE 3.1, GOVERN 6.2	Core clause
Same crosswalk topic	OWASP Agentic ASI04	Core clause
Same crosswalk topic	OWASP LLM LLM04:2026	Core clause
Same crosswalk topic	TC260 Framework 3.0 TC260 App. 2 II.4, TC260 4.4.4	Core clause
Same crosswalk topic	China Deep Synthesis DeepSyn Art. 14	Related clause
Same crosswalk topic	China GenAI Measures GenAI Art. 7	Related clause
Same crosswalk topic	G7 Code G7 Action 11	Related clause
Same crosswalk topic	GAO AI Accountability 2.6	Related clause
Same crosswalk topic	GPAI Code Transparency 1.2	Related clause
Same crosswalk topic	UK ATRS ATRS 2.1.4	Related clause

Patterns that build it

No pattern in the catalogue names this clause on its "Maps to" line yet; the artefact above is the engineering answer.

The same topic in other frameworks

From the topic crosswalk: the clauses filed under the same topics as this one. Mappings are illustrative, not a claim of conformity.

Supply chain and third parties

EU AI Act Art. 25 Responsibilities along the AI value chain (core)
ISO 42001 A.10 Third-party and customer relationships (core)
NIST AI RMF GOVERN 6 GOVERN 6: Policies and procedures are in place to address AI risks and benefits arising from third-party software and data and other supply chain issues (core)
NIST AI RMF MAP 4 MAP 4: Risks and benefits are mapped for all AI system components including third-party software and data (core)
NIST AI RMF MANAGE 3 MANAGE 3: AI risks and benefits from third-party entities are managed (core)
TC260 Framework 3.0 TC260 App. 2 II.4 Supply chain and tool management (core)
EU AI Act Art. 25(4) Written agreement with third-party suppliers (core)
GDPR Art. 28 Processor (core)
NIST AI RMF MANAGE 3.1 MANAGE 3.1: AI risks and benefits from third-party resources are regularly monitored, and risk controls are applied and documented (core)
CSA AICM STA-10 Supply Chain Risk Management (core)
CSA AICM STA-09 Service Bill of Material (BOM) (core)
OWASP LLM LLM04:2026 Supply Chain (core)
OWASP Agentic ASI04 Agentic Supply Chain Vulnerabilities (core)
AI Verify 9.7.1 Accountability: clear responsibilities between parties in the supply chain, set in service level agreements and contracts (core)
AI Verify 5.3.1 Security: secure the supply chain by assessing and monitoring its security risks across the life cycle (core)
AI Verify 4.5.2 Safety: continuously monitor third-party systems, with a fallback plan and contracts that assign liability (core)
EU AI Act Art. 26 Obligations of deployers of high-risk AI systems
TC260 Framework 3.0 TC260 4.4.4 Open-source ecosystem
China GenAI Measures GenAI Art. 7 Lawful data and model sources
China Deep Synthesis DeepSyn Art. 14 Providers and technical supporters
EU AI Act Art. 22 Authorised representatives of providers of high-risk AI systems
EU AI Act Art. 23 Obligations of importers
EU AI Act Art. 24 Obligations of distributors
GPAI Code Transparency 1.2 Providing relevant information
GDPR Arts. 44–46 Transfers to third countries
NIST AI RMF GOVERN 6.2 GOVERN 6.2: Contingency processes are in place to handle failures or incidents in third-party data or AI systems deemed to be high-risk
UK ATRS ATRS 2.1.4 Third party involvement
G7 Code G7 Action 11 Implement data input measures and protect personal data and intellectual property
GAO AI Accountability 2.6 Dependency: assess interconnectivities and dependencies of data streams that operationalize the AI system
AI Verify 9.3.1 Accountability: select AI system suppliers aligned with the organisation's approach, with remedial action when they underperform

Source

Chapter 08, section EU AI Act, post-Omnibus, checked against its sources on the review date above.

Machine-readable

This obligation: /api/v1/obligations/aige-obl-euaia-art54.json
The register: /api/v1/obligations.json · CSV
Schema and stability promise: open data and API

Cite this obligation

García Aibar, J. (2026). EU AI Act Art. 54: authorised representative of non-EU GPAI providers (AIGE-OBL-EUAIA-ART54). In AI Governance Engineering: The Thesis & Body of Knowledge (v0.5.0). https://doi.org/10.5281/zenodo.22956197. https://aigovernanceengineer.com/obligations/aige-obl-euaia-art54. CC BY 4.0

BibTeX

@misc{aige2026obligation,
  author       = {Jorge García Aibar},
  title        = {{EU AI Act Art. 54: authorised representative of non-EU GPAI providers (AIGE-OBL-EUAIA-ART54)}},
  howpublished = {In AI Governance Engineering: The Thesis \& Body of Knowledge},
  year         = {2026},
  version      = {0.5.0},
  doi          = {10.5281/zenodo.22956197},
  url          = {https://aigovernanceengineer.com/obligations/aige-obl-euaia-art54},
  note         = {Version 0.5.0}
}