Articles 22-25: value chain and authorised representative
Role shifts in the AI value chain and the mandatory representative for non-EU providers.
The official source remains authoritative. This general interpretation is not legal advice.
- Status
- Upcoming
- Application date
- 2 December 2027
- Version
- 1.0.0
- Last reviewed
- 8 August 2026
Who this is relevant to
When this applies
Deployer
An organisation using an AI system under its authority, excluding personal non-professional use.
Provider of an AI system
A party that develops or has an AI system developed and places it on the market under its own name.
- 1A high-risk system is supplied, modified, rebranded or placed on the Union market from outside the EU.
What the official source establishes
Article 25 provides that a distributor, importer, deployer or third party becomes the provider when it puts its name on a high-risk system, substantially modifies it or changes its intended purpose so it becomes high-risk; Article 22 obliges third-country providers to appoint a written authorised representative in the Union.
For the Annex III route this requirement applies from 2 December 2027; for high-risk AI in regulated products (Annex I) from 2 August 2028.
Our interpretation
The most dangerous role switch is the unintended one: your own layer on top of a procured model, your own brand on a tool, and you suddenly carry the full provider duties. This belongs as a standing question in every AI project.
What you can do now
Include the role question in the AI register and in project gates, and contractually define who supplies which information and cooperation on changes.
- 01
Assess the value-chain role per system and change
On white-labelling, substantial modification or purpose change, assess whether your organisation becomes the provider, and arrange the representative for non-EU supply.
What to retain
Value-chain file
Record per system of role, contractual arrangements on information and cooperation, and the appointment of a representative where required.
Control and reassessment
Role reassessment on every change
Repeat the role assessment on every rebranding, modification or new use of an existing system.
Public tools
Full text of Article 25
The full legal text in the public AI Act Explorer.
Conditions and exceptions
- Those acting solely as distributor or importer without the Article 25 triggers remain in that lighter role, with their own verification duties.
Official sources and locators
EU Artificial Intelligence Act 2024/1689
European Parliament and Council | original-oj-2024-07-12
Source locator: Articles 22 and 25
Digital Omnibus on AI 2026/1744
European Parliament and Council | official-journal-2026-07-24
Source locator: Amended Article 113 application dates
Version history
v1.0.0
27 July 2026
Articles 22-25: value chain and authorised representative
Role shifts in the AI value chain and the mandatory representative for non-EU providers.
Execution
From obligation to arranged and demonstrable
Knowing where you stand is step one. Embed AI translates this obligation into a concrete approach for your organisation: scope, ownership, register and evidence.
See the Embed AI approachFor AI agents and integrations
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