Authorized Representative Mandate

The authorized representative is legally obligated to maintain a copy of the technical documentation file for inspection. Key responsibilities include:

• Keeping the Declaration of Conformity readily available.
• Retaining records of the conformity assessment procedure.
• Providing all necessary information to demonstrate the AI system's compliance to National Competent Authorities upon reasoned request.

The representative is responsible for executing the registration process in the EU database. This involves submitting the provider's name, address, and contact details alongside the system's Unique Registration ID. The mandate ensures that a legal entity within the jurisdiction is accountable for the accuracy of the registration data and can be held liable for misrepresentation.

This mandate compels the representative to cooperate fully with National Competent Authorities on any action concerning the high-risk AI system. This includes facilitating post-market monitoring, providing access to logs, and assisting in the investigation of serious incidents. The representative acts as the operational proxy for the foreign provider during market surveillance audits.

The mandate remains valid until formally terminated. However, termination does not absolve the representative of liability for non-compliance that occurred during their tenure. If a representative terminates the mandate, the provider must immediately designate a replacement. Failure to maintain a valid representative constitutes a market access violation, triggering potential Market Withdrawal Notification procedures.

Before placing a non-EU AI system on the market, the Importer Compliance Gate requires verification that the foreign manufacturer has designated an authorized representative. The importer must confirm the written mandate exists and that the representative is capable of fulfilling the Post-Market Monitoring obligations. This creates a chain of accountability from the foreign developer to the Union end-user.

The principle of mutual recognition embedded in the EU AI Act allowing a single registration completed in one member state to serve as the legal basis for market access across all 27 member states. The Authorized Representative's physical establishment in one jurisdiction satisfies the mandate for the entire Union. This eliminates the need for multiple representatives, but requires the designated entity to be capable of coordinating with all National Competent Authorities simultaneously.

The legally binding document signed by the provider asserting that a high-risk AI system satisfies all applicable regulatory requirements. For non-EU providers, the Authorized Representative must hold a copy of this declaration and present it to authorities upon request. The document must include:

• The provider's name and registered trade name
• The Authorized Representative's name and address
• A statement of sole responsibility
• References to relevant harmonized standards

The alphanumeric identifier assigned by the EU database to a specific high-risk AI system upon successful registration. This ID serves as the primary traceability mechanism across the entire supply chain. The Authorized Representative must ensure this ID is affixed to the system, packaging, and accompanying documentation. It links the physical product to its digital compliance record and is the reference point for all post-market monitoring and incident reporting obligations.

The continuous, systematic process by which providers collect and analyze data on the real-world performance of an AI system. The Authorized Representative serves as the primary collection point for EU user feedback and must facilitate the provider's obligation to report serious incidents to National Competent Authorities. This includes maintaining a log of malfunctions, unintended behaviors, and safety risks that emerge after deployment, ensuring the registration file remains current.

A change to an AI system's intended purpose or performance characteristics that is significant enough to trigger a new conformity assessment and re-registration obligation. The Authorized Representative must be immediately informed of any planned modifications by the non-EU provider. If the representative determines the change is substantial, they must initiate a new registration process before the modified system can continue to be offered on the Union market, preventing regulatory drift.