EU Authorized Representative Prices for General AI Model Providers
- Mandatory appointment for non-EU providers of general AI models (Art. 54 AI Act)
- Published prices: from €420 to €1,490/year
- Included services: mandate, documentation retention, contact point
- Fines up to €15 million or 3% of global turnover for non-compliance
- Always compare what is included and renewal terms
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | €1.490/year (renewal €1.190) | Written mandate, EU representation, document retention 10 years, transparency notifications in 8 languages, public badge, no extra cost for EEA, request desk, verifiable certificate | Non-EU providers of general AI models or high-risk systems seeking full coverage and multilingual transparency |
| DPO Europesource | Netherlands | €950/year (first year) | On request | Providers seeking a basic service at a mid-range price |
| Prightersource | Germany | €420/year (Growth annual) | On request | Small non-EU companies looking for an economical option |
| Engage Compliancesource | United Kingdom | €690/year (Band 0) | On request | Start-ups and SMEs outside the EU |
| Praxikonsource | Netherlands | On request | Representation, technical documentation verification, record keeping 10 years, AI Office/authority contact point | Companies requiring technical verification and document management |
| AI Assurance Institutesource | United Kingdom | On request | Representation, AI Office/authority contact point | Providers seeking only formal representation |
Prices as published on each provider's website on 23 October 2026, excluding VAT unless stated. Each row links to its source.
Legal Requirements: Obligations and Key Articles
Regulation (EU) 2024/1689, known as the AI Act, introduces specific obligations for providers of general AI models established outside the European Union. According to Article 54, every non-EU provider intending to offer general AI models in the EU market must appoint an authorized representative based in the Union before market placement.
- Technical documentation verification: the representative must ensure that the technical documentation required by Annex XI has been prepared and that the obligations of Articles 53 and, if applicable, 55 are met.
- Documentation retention: technical documentation must be retained for 10 years after the AI model is placed on the market.
- Contact point: the representative acts as a liaison for the AI Office and competent national authorities, managing requests and official communications.
Failure to comply with these obligations may result in administrative fines up to €15 million or 3% of global turnover, whichever is higher (source). The appointment obligation does not apply to providers established in the EU, those using AI only internally without public output, or those conducting pure research and non-commercial personal use.
The law distinguishes between “providers” (those who develop or market the model) and “deployers” (those who use it): only non-EU providers are subject to the representative obligation, while deployers must ensure transparency (Art. 50) but do not necessarily have to appoint a representative.
How to Choose the EU Representative for the AI Act
Choosing the EU authorized representative is crucial for compliance and risk management. Here are the main practical criteria to consider:
- Annual price: ranges from €420 to €1,490 per provider, with differences between the first year and renewals. Some providers (e.g., REP27) offer discounted renewals.
- Included services: not all providers specify what is included. REP27 includes transparency notifications in 8 languages, public badge, request desk, verifiable certificate, and no extra cost for EEA coverage. Other providers (Prighter, Engage Compliance, DPO Europe) do not detail services on their websites.
- Experience and specialization: prefer providers with specific experience in AI representation, not just GDPR.
- Activation times: REP27 guarantees designation within 24 hours; other providers do not publish this data.
- Documentation management: 10-year retention is mandatory, but only some providers (e.g., Praxikon) explicitly declare this.
- Operational support: having a desk for user and authority requests is a plus for practical management.
Comparison table of included services:
| Provider | Included | Not included | Extra fees |
|---|---|---|---|
| REP27 | Mandate, notifications, badge, desk, multilingual, certificate, no extra EEA | Audit, compliance tests, Swiss representation | None declared |
| DPO Europe | On request | On request | On request |
| Prighter | On request | On request | On request |
| Engage Compliance | On request | On request | On request |
| Praxikon | Representation, technical verification, 10-year records | On request | On request |
| AI Assurance Institute | Representation, contact point | On request | On request |
Transparency on included services is essential: always request a detailed list before signing.
What the Price Really Includes: Pay Attention to Details
The published annual price from providers can cover very different services. For example:
- REP27 offers in the base price: written mandate, EU representation, management and retention of technical documentation for 10 years, transparency notifications in 8 languages, verifiable public badge, no extra cost for EEA coverage, request desk, verifiable certificate. Audits, compliance tests, or Swiss representation are not included.
- Praxikon declares technical documentation verification, 10-year record keeping, and contact point for AI Office/authorities.
- Other providers (DPO Europe, Prighter, Engage Compliance, AI Assurance Institute) do not publicly specify what is included: a written detail must be requested.
Be aware of:
- Possible extra costs for authority requests, additional languages, managing multiple systems, or annual updates
- Automatic renewals: check if the price changes after the first year
- Liability limits and geographic coverage (EEA only or also Switzerland?)
A practical comparison:
- If you have multiple AI models or high-risk systems, check if the provider charges per system or offers a flat rate.
- If you operate on marketplaces (Amazon, Etsy), ask if representation also covers marketplace requests.
Contractual clarity is essential to avoid surprises and unexpected costs.
Hidden Costs and Limits: What to Know Before Signing
Many providers do not publish details on additional costs, service limits, or exclusions. Here is what emerges from available data:
- REP27 explicitly states that audits, compliance tests, and Swiss representation are not included. The assessment for Switzerland is free, but actual representation is not offered.
- For DPO Europe, Prighter, Engage Compliance, AI Assurance Institute, details on extra costs, liability limits, response times, and handling multiple requests are "On request" and must be asked before signing.
- Praxikon offers technical verification and record management but does not specify extra costs or limits.
Other aspects to clarify:
- Notice for termination or automatic renewal: some providers automatically renew contracts unless explicitly canceled.
- Liability in case of error or failure to respond to authorities: most limit their liability contractually.
- Handling urgent requests: check if maximum response times are provided and if there are costs for out-of-hours requests.
Practical recommendation: always request a copy of the contract and verify every clause on costs, liability, and termination procedures before committing.
How the Appointment Works: Operational Steps
Appointing an EU representative for the AI Act follows a precise procedure. Here are the practical steps, valid for all providers:
- Verify obligation: ensure your company is established outside the EU and offers general AI models or high-risk systems in the EU market.
- Choose provider: compare prices, included services, and activation times. Always request a detailed offer.
- Onboarding: fill out the form with company data, AI systems description, roles (provider/deployer), and distribution methods in the EU.
- Sign mandate: the provider sends a written mandate (often electronically signed) formalizing representation.
- Receive documents: receive the appointment certificate, instructions for transparency notifications (if included), and AI systems register.
- Implementation: publish transparency notifications on required channels, retain technical documentation, and update the systems register.
- Manage requests: in case of requests from authorities or users, the provider forwards and responds within contractually agreed times.
For REP27, designation is issued within 24 hours. For other providers, times are not declared and must be requested. The procedure can also be managed via AWS Marketplace (REP27), simplifying billing and onboarding for those already using AWS.
Operational checklist:
- Verify if your AI model is general purpose and intended for the EU market
- Identify your company’s legal seat
- Request detailed quotes from selected providers
- Ask what is included and if there are extra costs
- Prepare technical documentation required by Annex XI
- Sign the mandate with the chosen representative
- Implement transparency notifications and retain the certificate
- Prepare an internal procedure to respond to authority requests
Risks and Penalties: What Happens If You Don't Appoint a Representative
Failure to appoint an EU representative entails concrete risks and serious penalties:
- Administrative fines: up to €15 million or 3% of global turnover, as provided by the AI Act. Authorities may apply the higher penalty.
- Exclusion from the EU market: without a representative, it is legally impossible to offer general AI models or high-risk systems in the EU market. This can lead to product removal from platforms and marketplaces.
- Loss of B2B customers: many companies and platforms require proof of compliance as a prerequisite for collaborations or contracts.
- Reputational risk: lack of transparency or non-compliance can damage corporate reputation and lead to loss of trust from partners and customers.
- Information requests: authorities can request technical documentation and proof of appointment at any time. Failure to respond promptly can worsen the company’s position.
Compliance is not only a legal matter but also commercial: it is often required by customers, investors, and international marketplaces. Traceability of the appointment and immediate availability of documentation are key to avoiding blocks and penalties.
Practical scenario: a US SaaS offering a generative AI model in the EU without a representative risks both administrative fines and removal from major marketplaces and loss of corporate clients.
Decision Matrix: Who Needs an EU Representative and Who Does Not
| If you are... | Do you need to appoint a representative? | Notes |
|---|---|---|
| Non-EU provider of general AI models (B2B/B2C) | Yes | Mandatory (Art. 54) |
| EU provider | No | Not required |
| Marketplace (Amazon, Etsy, eBay) with non-EU seat | Yes | If offering general AI models in the EU |
| Seller using AI only internally, no public output | No | Subject only to internal transparency |
| Pure research, non-commercial personal use | No | Exempt from obligation |
| Chinese seller on Amazon offering an AI system in the EU | Yes | Obligation if system is sold in the EU |
| UK start-up selling its own AI model in the EU | Yes | EU representative obligation |
| US company using AI only for internal processes | No | No representative obligation |
The matrix helps quickly understand if your company falls under the obligation. In case of doubt, many providers (e.g., REP27) offer a free check to assess the specific situation.
What Providers Usually Don't Say
- Extra costs: many providers do not disclose if there are costs for additional requests, extra languages, or managing multiple systems. REP27 specifies no extra costs for EEA or standard requests but does not offer audits or technical tests.
- Liability limits: most providers contractually limit their liability; always check the clauses.
- Notice and renewal: some providers automatically renew contracts unless canceled; check notice terms and cancellation procedures.
- Territorial exclusions: representation in Switzerland is not included; REP27 only offers a free assessment for Swiss obligation.
- Services not included: audits, compliance tests, in-depth technical assessments, and representation for other regulations (e.g., GPSR, GDPR) are separate services.
Practical advice: always request a written and detailed list of included services, exclusions, and renewal/cancellation conditions before signing.
3 Practical Scenarios: Which Obligation and Solution
- US SaaS offering a generative AI model in the EU: Must appoint an EU representative (Art. 54), provide technical documentation and transparency notifications. Solution: REP27 for full and multilingual coverage, or Prighter for an economical option, depending on budget and transparency needs.
- Chinese seller on Amazon using AI for recommendations: If the AI system is sold as a product/service in the EU, representative obligation applies. If internal use only, no obligation. Solution: REP27, Engage Compliance, or Praxikon, verifying marketplace request coverage.
- UK online shop selling its own AI model in the EU: EU representative obligation, with options including REP27, Engage Compliance, or others. If the model is high-risk, document management for 10 years is also required.
In all scenarios, compliance starts with verifying the nature of the AI model (general or high-risk), legal seat, and method of offering in the EU market.
When you do not need this
No need to appoint an EU representative if:
- Your company is established in the EU
- You use AI only internally without public output
- You conduct pure research or non-commercial personal use
- You offer services only outside the EU market
Frequently asked questions
Who must appoint an EU representative under the AI Act?
Every provider established outside the EU offering general AI models or high-risk AI systems in the EU market must appoint an authorized EU representative before market placement, as required by Art. 54 of the AI Act.
What happens if I don't appoint a representative?
Failure to appoint results in fines up to €15 million or 3% of global turnover, plus risk of commercial block and loss of customers or marketplaces. Authorities can request documentation and proof of appointment at any time.
Does the price also cover representation in Switzerland?
No, representation in Switzerland is not included in REP27's or other listed providers' services. REP27 offers a free assessment for Swiss obligation and, if not required, a signed exemption statement.
How long does it take to be appointed?
REP27 issues designation within 24 hours of receiving data and payment. Other providers do not declare times and must be contacted directly.
Are there extra costs beyond the annual price?
REP27 does not charge extra for requests, languages, or EEA coverage. For other providers, this information is not published and must be requested before signing.
Is a representative needed for each AI model?
Appointment is required for each provider placing general AI models on the EU market. Some providers may manage multiple systems under one mandate, but this must be verified case by case.
What must the EU representative do?
They must retain technical documentation, respond to authorities, forward requests, and ensure transparency and safety obligations are met for AI models offered in the EU market.
Can I change the representative later?
Yes, you can change representatives, but authorities must be notified and documentation updated. Check notice and termination terms in the contract with the chosen provider.
Can the EU representative be a natural person?
The law requires the representative to be established in the EU; it can be a natural or legal person, but most providers offer the service via specialized companies to ensure continuity and traceability.
Does the service also cover transparency (Art. 50 notifications)?
REP27 includes transparency notifications in 8 languages and a public badge. For other providers, notification coverage must be verified as not all include it in the base price.
Is it also required for those selling via marketplaces (Amazon, Etsy)?
Yes, if the AI model is offered in the EU market via marketplaces, the appointment obligation remains valid for the non-EU provider.
What happens if I change provider during the year?
The new representative must be formally appointed and authorities informed. It is important to manage the transition without interruptions to avoid non-compliance periods.
Sources
- REP27 — Europe Services, SE — AI Act — gdprrepresentative.com
- DPO Europe — EU AI Act Authorised Representative — data-privacy-office.eu
- Prighter — General Purpose AI Representative — prighter.com
- Engage Compliance — AI Act Representative — engagecompliance.co
- Praxikon — Gemachtigde AI — praxikon.com
- AI Assurance Institute — Authorised AI Representative — aiassurance.institute
- AI Act Service Desk — Article 54 — ai-act-service-desk.ec.europa.eu
- REP27 — Penalties and Comparisons — gdprrepresentative.com
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