Articles 22 & 54 · non-EU providers
Does a U.S. AI company need an EU representative?
Sometimes. EU representative obligations are not triggered merely because a U.S. company is in AI Act scope. The answer depends on the company's role and whether it provides a high-risk AI system or a general-purpose AI model covered by the relevant representative provision.
Updated and legally reviewed: 29 September 2026.
Direct answer
Being a non-EU company is only the first question.
A U.S. deployer, customer or ordinary downstream user should not automatically assume it needs an authorised representative. Articles 22 and 54 attach representative duties to specified non-EU provider situations.
High-risk AI provider
Article 22 addresses providers of high-risk AI systems established in third countries in the circumstances set out by the Act. The mandate and representative tasks should be documented.
GPAI model provider
Article 54 separately addresses authorised representatives of providers of general-purpose AI models established in third countries, subject to the Act's conditions and exceptions.
Common mistake
Do not confuse representative, importer and distributor roles.
The AI Act assigns different functions to these actors. Contract labels should not replace a role analysis based on what each organisation actually does in the AI value chain.
Free checker
Screen your representative exposure.
The checker separates high-risk-system provider and GPAI-provider routes and flags when a role or exception needs further verification.