Art.54
EU AI Act Guide › Chapter V — General-Purpose AI Models › Article 54

Article 54 — Authorised Representatives of Providers of General-Purpose AI Models

GPAI Models SME Relevant ~2 min read · 463 words

Article 54 mirrors the authorised representative requirement of Article 22 — but for general-purpose AI models rather than high-risk AI systems. Non-EU providers of GPAI models that are placed on the EU market or used in the EU must appoint an EU-based authorised representative before making their model available. This article catches every major US-based AI company offering models in Europe.

✓ Low compliance impact for SMEs

WHAT THE ARTICLE IS ABOUT

The EU gateway representative requirement for non-EU GPAI providers

Article 54 establishes the authorised representative obligation for GPAI model providers established outside the EU. Any company based in the US, UK, or elsewhere that makes a general-purpose AI model available for use in the EU must have an EU-based legal representative who can engage with the AI Office and national authorities on their behalf.

WHAT IT SAYS

Written mandate, EU establishment, Commission notification

  • Providers of GPAI models established in third countries who place their models on the EU market or make them available for use in the EU must appoint an authorised representative established in the EU
  • The appointment must be made by written mandate before the model is made available in the EU
  • The authorised representative must be named in the documentation accompanying the model and registered with the AI Office
  • The representative must have sufficient powers and resources to fulfil the provider’s obligations under Chapter V — including cooperating with the AI Office on investigations and maintaining documentation
  • The representative may be held liable alongside the provider for non-compliance
  • The appointment does not relieve the provider of their own obligations under Articles 53 and 55 — both remain responsible

WHO IS AFFECTED

Every non-EU GPAI provider with European users

  • US-based AI companies — OpenAI, Anthropic, Google, Meta, and all similar companies offering GPAI models to European users
  • UK-based GPAI providers post-Brexit
  • Any company anywhere in the world whose GPAI model is accessed or used by EU-based individuals or businesses
  • EU-based entities willing to act as authorised representatives for non-EU GPAI providers — potentially a significant new professional services market

WHAT IT MEANS FOR SMES

Ensures your US-based AI vendor has EU accountability

  • For EU-based SMEs using GPAI models from non-EU providers: Article 54 ensures your vendor has a legal presence and point of accountability within the EU — making it easier to enforce your rights under Article 53
  • Ask your non-EU AI vendor who their EU authorised representative is and how to contact them — this is public information they are required to provide
  • The representative is your practical escalation point if the provider is unresponsive or if you need to raise compliance concerns with EU authorities
  • For non-EU SMEs entering the EU AI market with a GPAI model: appointing an authorised representative is one of your first compliance steps — budget for this before your EU launch
  • The representative market is still developing — law firms, compliance consultancies and EU subsidiaries of tech companies are the most likely candidates

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