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EU AI Act Article 22: authorised representatives for non-EU providers

Article 22 requires providers of high-risk AI systems established outside the European Union to appoint, by written mandate, an authorised representative established in the Union, before making the system available on the EU market.

What the mandate must cover

Article 22(3) lists the tasks the authorised representative must be able to perform: verify that the EU declaration of conformity and technical documentation have been drawn up and that an appropriate conformity assessment procedure was carried out; keep the technical documentation, EU declaration of conformity and, where applicable, the notified body's certificate at the disposal of authorities for ten years; provide authorities with the information and documentation necessary to demonstrate conformity, on a reasoned request; cooperate with authorities on any action taken in relation to the system; and register the system if the provider failed to do so.

Who it applies to

Non-EU providers of high-risk AI systems. It does not apply to providers established in the Union, and GPAI providers have a separate, similarly-structured representative requirement under Article 54.

What evidence this implies

A written mandate naming the representative and its tasks; a live copy of the technical documentation and declaration of conformity actually held by the representative, not just referenced; and a working channel for authorities to reach the representative and get a substantive answer.

Gaps to state honestly

Appointing a representative is a legal and organisational act — the mandate itself is not something a logging tool can generate. What matters for evidence purposes is that the representative's copy of "what the system does" stays current and verifiable rather than a stale PDF. See our technical documentation guide for what that documentation should contain.

How Vetro helps

Vetro's hash-chained, ed25519-signed ledger gives the authorised representative something concrete to hold and hand to authorities: a verifiable record of the system's actual calls and decisions, not just static documentation. Vetro Attest verifies it for free, and for 49 USD produces a counter-signed report mapping it to the Act. Not legal advice.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.