EU Authorized Representative for AI Outside the Union: Obligations, Prices, and Selection (2026)

• Obligation for non-EU providers of high-risk AI or general-purpose models (Art. 22, 54)
• Not required for internal use or AI without contact with EU public
• Annual prices from €420 to €1,490 (verified October 2026)
• Includes: written mandate, notifications, document retention (10 years)
• Up to €15 million fine for missing representative
• Checklist and practical scenarios to determine if needed

Updated 26 October 2026 · 8 sources checked

Providers compared

Prices as published on each provider's website on 26 October 2026, excluding VAT unless stated. Each row links to its source.

What the Law Requires: Key Articles, Obligations, and Practical Cases

EU Regulation 2024/1689 (AI Act) governs the use and marketing of artificial intelligence systems within the European Union. If your company is established outside the EU and intends to offer AI systems or general-purpose models to European users, you may be required to appoint an authorized representative based in the EU. Here are the main legal references:

• Article 22: Non-EU providers of high-risk AI systems (e.g., for employment, credit, biometrics, security) must appoint an EU authorized representative before making the system available on the EU market (source).
• Article 54: Non-EU providers of general-purpose AI models (GPAI) must appoint an EU representative before placing the model on the market within the Union (source).
• Article 50: All providers (including EU-based) must provide transparent notices to EU users if the AI generates content or interacts with people (chatbots, images, audio, video, deepfakes).

Appointment is not required if:

• The AI is used only internally and does not interact with EU users.
• The activity is pure research, personal use, or non-commercial open source (with some exceptions for high-risk or prohibited systems).
• The company is already established in the EU.

The EU representative is the official contact point for authorities and users, must retain technical documentation and the declaration of conformity for 10 years (source).

Inclusions/Extras Table:

The table shows that only REP27 explicitly declares Swiss coverage (nFADP) and production of public badges and multilingual texts. No provider includes audits or technical tests.

How to Choose the Representative: Decision Matrix, Checklist, and Practical Criteria

Choosing an EU authorized representative for the AI Act depends on various practical and regulatory factors. Not all providers offer the same level of service or price. Here's how to navigate:

• Type of AI: If you offer a general-purpose model (GPAI) or a high-risk system, appointment is mandatory. For chatbots or AI generating content visible to the EU public, at least transparency (Art. 50) is required.
• Country of establishment: Only those outside the EU must appoint a representative. If you have an EU base, it is not required.
• Target market: If the AI is used or sold to EU users (B2C or B2B), the obligation applies. If only internal use or research, no.
• Sales channels: If you sell via marketplaces (Amazon, Etsy, eBay) and the AI is your own, the obligation applies. If you only use platform tools, usually no.
• Budget and additional services: Prices vary widely: from €420 to €1,490/year, with different services (see table). Some providers offer public badges, multilingual texts, Swiss coverage.

Decision matrix:

Practical checklist:

1. Check if your AI system is high-risk or general-purpose
2. Verify if your company is outside the EU
3. Assess if AI output reaches EU users (directly or via partners/marketplaces)
4. If yes, select provider and gather technical documentation
5. Appoint the representative with a written mandate
6. Prepare transparent notices (Art. 50) in all required languages
7. Retain documents for 10 years
8. Check if Swiss coverage (nFADP) is also needed

This checklist helps quickly evaluate if and which representative to appoint, avoiding unnecessary costs or sanction risks.

What the Price Really Includes: Services, Limits, and Hidden Costs

The annual price published by providers generally covers:

• Written mandate as EU representative (Art. 22/54 AI Act)
• Retention of technical documentation and declaration of conformity for 10 years
• Response to requests from authorities and EU users
• Texts for transparent notifications (Art. 50), where declared
• Register of AI systems and annual updates (where applicable)

Practical comparison:

• REP27 includes, in the price, a verifiable public badge, texts in 8 languages, AI register, response to requests within 2 working days, Swiss coverage (nFADP) with assessment and exemption declaration if Swiss representative not needed. Does not include audits, technical tests, conformity assessments (openly declared).
• DPO Europe, Prighter, Engage Compliance declare only representation, without public details on texts, badges, languages, or Switzerland.
• Other providers (CRA-Portal, DataShield, VATAi, URIEL Consult) also offer services for the Cyber Resilience Act but do not specify details on AI transparency or extras.

Hidden costs and limits:

• Audits, technical assessments, or conformity tests are not included by any provider (REP27 declares this, others do not specify).
• Public badge, extra languages, Swiss coverage, or multi-market services may be excluded or charged extra if not explicitly declared.
• Possible extras for updates, out-of-standard requests, multi-market services, or early termination.
• Provider liability always remains with you: the representative is only a contact point.

Always verify in advance what is included and request a written list of services covered by the price.

How Appointment Works: Step by Step with Concrete Examples

Appointing an EU representative for the AI Act follows a precise procedure, which may vary slightly between providers. Here's a detailed guide based on information from REP27 and competitors:

1. Choose the provider and plan: Consult the price table and verify which services are included. For example, REP27 offers three plans (transparency, register+transparency, AI Act representative) with increasing prices and services.
2. Fill out the onboarding form: You will need to provide company data, description of AI systems, risk classification (high risk/general AI), target markets, sales channels (B2B, B2C, marketplace), and, if requested, answer questions about Switzerland.
3. Receive signed mandate and certificate: The provider issues a written mandate (with eIDAS electronic signature for REP27), a publicly verifiable certificate (QR code, badge), and, if applicable, transparency texts in multiple languages.
4. Prepare and publish transparency texts: Publish notices provided by the provider on chatbots, generated content, deepfakes, etc. (Art. 50). REP27 also indicates where to place each notice (e.g., first chatbot message, under images, email footer).
5. Retain technical documentation: You must keep updated and accessible the technical documentation and declaration of conformity for 10 years. The representative stores and produces it upon authority request.
6. Respond to authority requests: The EU representative is the contact point for supervisory authorities and users. REP27 guarantees forwarding requests within 2 working days.
7. Renew annually: The appointment is valid for one year and must be renewed. Some providers offer renewals at reduced price.

Practical example: With REP27, designation occurs within 24 hours of payment. On AWS Marketplace, the process is integrated into AWS billing, with no need for new providers.

Risks, Fines, and What Happens If You Don't Appoint a Representative

Failure to appoint an EU representative when mandatory is an independent violation of the AI Act. Authorities can sanction even without other offenses. Here are the concrete risks:

• Administrative fines: Up to 15 million euros or 3% of global turnover for violating transparency or representation obligations (Art. 50 and 54 AI Act). For prohibited practices, fines rise to 35 million or 7%.
• Commercial exclusion: Marketplaces, app stores, and enterprise clients increasingly require proof of appointment and public badge. Absence of a representative can lead to platform exclusion or contract loss, even before fines.
• Requests for clarification: Authorities and clients may request at any time copies of the mandate, transparency texts, and technical documentation. Failure or late response is considered an aggravating factor.
• Notification obligation: From September 11, 2026, non-EU manufacturers must notify EU authorities of the representative appointment (source).

Scenario: A US provider offering a general AI model to EU clients without a representative risks high fines and suspension from marketplaces and loss of key clients. Authorities do not ask if you knew the deadline: they ask where your notices are and who answers for you.

What Providers Usually Don't Say: Exclusions, Limits, and Practical Notices

• Representation covers only formal obligations: Audits, technical tests, and conformity assessments are not included (REP27 declares this, others do not specify). You must engage third parties for these activities.
• Limited liability: The EU representative is only a contact point for authorities and users. Legal responsibility and compliance always remain with the AI provider.
• Public badge, extra languages, Switzerland: Not all providers include verifiable badges, multilingual texts, or Swiss coverage. REP27 offers this; others do not specify.
• Notifications and annual reviews: The obligation to keep transparency texts and AI register updated is annual. Check if the provider includes or charges for this.
• Termination timing and provider change: Some providers may require notice or specific procedures for early termination or representative change. Always check contract terms.
• Multi-market services: If you also sell in UK, USA, or Switzerland, verify if the provider offers combined coverage or if separate representatives are needed.

Always request a written list of included services and exclusions to avoid surprises after appointment.

Practical Scenarios: Obligations and Simplest Compliance Path

• US SaaS Startup: Offers AI chatbots to EU clients via website and API. Must appoint EU representative (Art. 50, 54), publish transparent notices in all required languages, and retain technical documentation for 10 years. Solution: REP27 (EEA+Switzerland coverage, multilingual texts) or Prighter (if budget limited, but no declared public badge).
• Chinese Amazon Seller: Integrates proprietary AI for product recommendations to EU customers. If AI is developed and managed by the seller, appointment is mandatory (Art. 22/54). If only platform tools are used, no. Path: assess if AI is "own" and, if yes, appoint representative and publish notices.
• UK Online Shop: Uses AI only for internal analysis (e.g., warehouse optimization), no output to EU customers. No representative obligation. If in future AI generates content or interacts with EU users, transparency obligation (Art. 50) applies but no representative if company is EU-based.

In all cases, compliance starts from correct AI system classification and target market assessment. The simplest path is:

1. Classify your AI (high-risk/general/other)
2. Verify if it reaches EU users
3. Choose provider and gather documentation
4. Appoint representative and publish notices
5. Keep documents and notifications updated