EU AI Act Authorised Representative for Non-EU AI Providers: Providers & Prices (2026)
- Required for non-EU providers placing AI on the EU market (Art. 54, 22)
- 2026 prices range from EUR 420–1,490/year; inclusions differ by provider
- REP27 details fixed-fee, multilingual notices, public badge, and documentation desk
- Legal advice, DPO, or compliance assessments are not included by default
- Fines for non-compliance: up to €15M or 3% of global turnover
- Appointment process and obligations differ for providers and deployers
Providers compared
| Provider | Established in | Published price | What the price includes | Best for |
|---|---|---|---|---|
| REP27 — Europe Services, SE | Czech Republic | EUR 1,490/year (renewal EUR 1,190) | Mandate under Art. 22/54, technical documentation holding, public badge, multilingual notices, 10-year record retention, request desk | Non-EU AI model/system providers needing full transparency and documentation |
| Prightersource | Germany | EUR 420/year | On request | On request |
| Engage Compliancesource | United Kingdom | EUR 690/year | On request | On request |
| DPO Europesource | Netherlands | EUR 950/year (first year) | On request | On request |
Prices as published on each provider's website on 16 October 2026, excluding VAT unless stated. Each row links to its source.
What the EU AI Act Requires (with Article Numbers)
The EU AI Act (Regulation (EU) 2024/1689) is the world’s first comprehensive legal framework for artificial intelligence. It entered into force on 1 August 2024 and applies in stages through to 2030, regulating AI by risk rather than by technology (source, source). The Act covers any provider, deployer, importer, or distributor placing AI systems or general-purpose AI models (GPAI) on the EU market, regardless of where the company is based. Non-EU providers must appoint an authorised representative established in the EU (Art. 54 for GPAI models, Art. 22 for high-risk systems). This representative acts as the official contact for EU authorities, holds technical documentation, and ensures that transparency and marking requirements are met.
The Act distinguishes between providers (who develop or place AI systems/models on the market) and deployers (who use them). Providers outside the EU must have a representative before offering their AI in the EU. The law is risk-based: prohibited practices (Art. 5), high-risk systems (Annex III, Art. 22), transparency-risk systems (Art. 50), and minimal risk, with separate rules for GPAI (Art. 54). Transparency requirements (Art. 50) already apply from 2 August 2026, including clear notices for chatbots, AI-generated content, and deep fakes. High-risk system obligations start 2 December 2027. Fines for non-compliance can reach €15 million or 3% of global turnover for missing a representative, and up to €35 million or 7% for prohibited practices (Art. 99).
Internal-only AI use (no public or customer-facing AI, no output visible to EU individuals) is generally exempt from the representative requirement. The law follows the AI’s output and its impact in the EU, not the server location or company headquarters.
How to Choose an EU AI Act Authorised Representative
When selecting an EU AI Act authorised representative, it is essential to consider both compliance and practical support. The representative’s role is strictly defined by law: they must be established in the EU, accept a written mandate (Art. 22/54), hold technical documentation for 10 years, and act as the contact point for authorities. However, the scope of included services varies widely between providers.
- Mandate and Documentation: Confirm the provider offers a formal written mandate under the correct Article (22 or 54) and will hold your technical file for the full 10-year period.
- Transparency Notices: Some providers, such as REP27, include multilingual transparency notices and placement guides, ensuring you meet Article 50 requirements for chatbots, AI content, and deep fakes. Others may not specify this service.
- Public Verification: A public badge or certificate can help demonstrate compliance to platforms, partners, or authorities. REP27 provides a QR-coded badge and public verification page.
- Request Handling: Check if the provider forwards requests from authorities or data subjects and in which languages. REP27 offers a request desk in 8 languages, forwarding within 2 business days.
- Legal Advice and DPO: No provider in this comparison includes legal advice, DPO services, or compliance assessments by default. These must be sourced separately if needed.
Below is a comparison of included and excluded features for each provider (as published):
| Provider | Included | Not Included | Extra Fees |
|---|---|---|---|
| REP27 | Mandate, documentation holding, multilingual notices, public badge, request desk | Legal advice, DPO, compliance assessment | None stated |
| Prighter | On request | On request | On request |
| Engage Compliance | On request | On request | On request |
| DPO Europe | On request | On request | On request |
Always request a detailed service description and contract before appointment, as hidden costs or exclusions may apply.
What the Price Really Includes
Published prices for EU AI Act authorised representative services (as of October 2026) range from EUR 420 to EUR 1,490 per year. However, what you get for this fee varies:
- REP27 — Europe Services, SE: EUR 1,490/year (renewal EUR 1,190). Includes a written mandate under Art. 22/54, 10-year documentation holding, multilingual transparency notices (up to 8 languages), a public verification badge, and a request desk. No legal advice, DPO, or compliance assessment is included. There are no time-based or per-request fees stated. The service is suitable for non-EU AI providers needing comprehensive documentation and public compliance proof.
- Prighter: EUR 420/year (Growth plan). Service inclusions are not detailed on the source page. Buyers should request a full breakdown before appointment. The price is lower, but the scope may be more limited.
- Engage Compliance: EUR 690/year (Band 0, smallest band). The source page does not specify what is included. Clarify before purchasing, especially for technical documentation and public verification.
- DPO Europe: EUR 950/year (first year). Service details are not published on the source page. Buyers should confirm if documentation holding, notices, and public badge are included.
Legal advice, DPO services, and compliance assessments are not included by default by any provider. If your business needs these, they must be sourced separately. Always check for renewal pricing, as some providers (e.g., REP27) offer a lower renewal rate after the first year.
Practical tip: Ask each provider for a sample mandate, a list of included deliverables, and their process for handling authority requests before signing.
Hidden Costs and Exclusions
While headline prices are published, many providers do not disclose details on extra fees, per-request charges, or liability limits. This can lead to unexpected costs or compliance gaps. Here’s what to look for:
- Notice Periods: Check the contract for cancellation terms. Some providers may require advance notice before termination or renewal.
- Per-System or Per-Request Fees: REP27 charges a single fee per system, with no time-based or per-request surcharges stated. Other providers do not publish this information; always clarify if you have multiple AI systems or expect frequent authority requests.
- Liability Limits: The law (Art. 54(5)) states the representative does not shield your company from enforcement. Most providers limit their liability for compliance failures. Confirm this in the contract.
- Renewal Pricing: REP27 publishes a lower renewal rate (EUR 1,190 after the first year). Other providers may have different renewal terms—always check for price increases.
- Scope Exclusions: No provider in this comparison includes legal advice, DPO, or compliance assessment as part of the standard fee. REP27 states this explicitly; for others, request written confirmation.
Below is a summary of typical exclusions and potential extra fees (as published):
| Provider | Notice Period | Per-System Fees | Liability Limit |
|---|---|---|---|
| REP27 | Not published | Single fee per system | Mandate does not shield from enforcement |
| Prighter | On request | On request | On request |
| Engage Compliance | On request | On request | On request |
| DPO Europe | On request | On request | On request |
Always request the full contract and clarify all terms before appointment.
How Appointment Works: Step by Step
Appointing an EU AI Act authorised representative is a process that requires careful preparation and documentation. Here is a practical, step-by-step guide based on the law and provider practices:
- Determine Applicability: Confirm if your company is a provider under the AI Act (i.e., you place AI systems or GPAI models on the EU market). Use the decision matrix below for guidance.
- Classify Your AI System: Identify if your system is high-risk (Annex III), a general-purpose model, or minimal risk. This affects which obligations and deadlines apply.
- Choose a Provider: Compare published prices, inclusions, and exclusions. Request a sample mandate and list of deliverables.
- Prepare Documentation: Gather your technical file, system description, intended use, and compliance records. REP27 requires this for mandate issuance.
- Sign the Mandate: The provider issues a written mandate under Art. 22/54. REP27 delivers this within 24 hours after receiving documentation.
- Receive Confirmation: Obtain a signed designation letter, public verification badge, and instructions for transparency notices. REP27 provides notices in up to 8 languages and a QR-coded badge.
- Publish Notices: Place required transparency notices on your website, chatbot, or AI-generated content as instructed. Keep all versions and records for 10 years.
- Ongoing Updates: Update the mandate and documentation if your AI system changes. Review compliance annually or on each significant change.
Checklist for today:
- Identify your AI system’s market presence in the EU
- Classify risk level
- Contact providers for detailed offers
- Prepare and submit documentation
- Sign and implement the mandate
- Publish and record all required notices
- Maintain records and review regularly
Risks and Fines for Non-Compliance
Failing to appoint an EU AI Act authorised representative exposes non-EU AI providers to significant risks. The law imposes fines up to €15 million or 3% of global annual turnover for missing the representative requirement (Art. 99). For prohibited practices, fines can reach €35 million or 7%. These penalties are among the highest in EU digital regulation, reflecting the seriousness of AI compliance.
Commercial risks are also substantial. Platforms, app stores, and large business customers routinely require proof of AI Act compliance, including the representative’s mandate and public verification. Without this, companies may lose contracts or be delisted before any regulatory fine is imposed.
Internal-only AI use (i.e., AI not exposed to EU individuals or the public) is generally exempt from the representative requirement. However, if your AI system or its output is accessible in the EU—even indirectly via partners or marketplaces—you must comply.
Practical tip: Keep all versions of transparency notices and mandate records. Authorities may ask for historical evidence of compliance, not just your current status. REP27 provides date-stamped records and a public badge for this purpose.
Remember: The representative does not shield your company from enforcement. You remain fully liable for compliance, and the representative’s role is to facilitate communication and record-keeping, not to answer on the merits or provide legal defence.
Decision Matrix: Do You Need an EU AI Act Representative?
| If you are ... | You need ... | You do NOT need ... |
|---|---|---|
| Non-EU company, selling AI models/systems in EU (B2B/B2C) | EU AI Act authorised representative (Art. 22/54) | If only using AI internally, no public output |
| Non-EU marketplace seller (Amazon, Etsy, eBay) | Representative if selling AI-enabled products/systems | If only selling non-AI goods |
| EU-based company | No representative needed | — |
| Non-EU company, internal AI tools only | Usually exempt | Representative |
| Non-EU SaaS with AI chatbot for EU users | Representative required | Not needed if chatbot is not available to EU users |
| Chinese AI hardware vendor with embedded AI features | Representative required if sold in EU | Not needed if not sold in EU |
Always check your system’s exposure and role before deciding.
Scenarios: What Applies and How to Comply
- US SaaS company with AI chatbot for EU users: The company is a provider under the AI Act, as its chatbot interacts with EU individuals. It must appoint an EU AI Act authorised representative, provide technical documentation, and publish transparency notices. REP27 offers a full package (mandate, notices, public badge) for EUR 1,490/year. Prighter and Engage Compliance also serve this need, but details of included services must be confirmed.
- Chinese Amazon seller offering AI-enabled product: If the product includes AI features (e.g., smart camera, recommendation engine), the seller is a provider and must appoint a representative. The process: select a provider, sign the mandate, supply documentation, and publish required labels. REP27 and Engage Compliance both offer this service; buyers should request details on documentation handling and badge issuance.
- UK online shop using internal AI for logistics only: If the AI is not exposed to EU customers and only used for internal process optimisation, no representative is needed. If the shop deploys AI chatbots or recommendation engines visible to EU users, the obligation applies.
These scenarios illustrate the importance of mapping your AI’s exposure and role. If in doubt, consult the law’s definitions (Art. 3) and seek written confirmation from your chosen provider.
What Providers Usually Do Not Say
- Mandate Scope: The representative’s mandate does not cover legal advice, DPO work, or compliance assessment. REP27 states this explicitly; for others, request written confirmation.
- Liability: The representative does not shield your company from enforcement actions. You remain fully liable for compliance failures (Art. 54(5)).
- Extra Fees: Some providers may charge per AI system, per request, or for additional documentation. REP27 publishes a single fee per system, but others do not specify. Always confirm in writing.
- Notice Periods: Contracts may require notice before cancellation or renewal. These terms are rarely highlighted on marketing pages.
- Renewal Pricing: Initial and renewal rates may differ. REP27 publishes both; others may not.
- Transparency Notices: Not all providers offer multilingual notices or placement guides. If you need these, confirm they are included.
Practical tip: Always request the full contract, a list of deliverables, and a sample mandate before appointment. Clarify all terms, especially for multi-system coverage and request handling.
When you do not need this
Companies using AI only for internal processes, with no interaction or output visible to EU individuals, generally do not need an EU AI Act authorised representative. EU-based companies do not need a representative. Sellers of non-AI goods on marketplaces are also exempt.
Frequently asked questions
Who must appoint an EU AI Act authorised representative?
Any non-EU company that places AI systems or general-purpose AI models on the EU market—whether direct to consumers or via partners—must appoint an EU-based authorised representative under Articles 22 and 54 of the EU AI Act. Internal-only use is usually exempt.
What does an EU AI Act authorised representative do?
The representative acts as the official EU contact for authorities, holds technical documentation for 10 years, forwards requests, and ensures transparency notices are in place. They do not provide legal advice or answer compliance questions on your behalf.
What is the penalty for not appointing a representative?
Fines can reach up to €15 million or 3% of global turnover for non-compliance with the representative requirement. Prohibited practices can trigger even higher fines—up to €35 million or 7%.
How quickly can I appoint a representative?
REP27 issues mandates within 24 hours after receiving documentation. Other providers’ timescales are not published—check directly with each provider for their process and lead time.
What is included in REP27’s service?
REP27 includes a written mandate, documentation holding for 10 years, multilingual transparency notices (up to 8 languages), a public verification badge, and a request desk. Legal advice, DPO services, and compliance assessments are not included.
Does the representative answer data subject or authority requests?
REP27 forwards requests to your company within 2 business days but does not answer on the merits. You remain responsible for substantive responses to authorities or data subjects.
Can I use the same representative for GDPR and the AI Act?
No. The GDPR (Article 27) and the AI Act require separate mandates, as they cover different obligations and roles. REP27 offers both, but each is a distinct contract and must be appointed separately.
Do I need a representative for AI used only internally?
No. If your AI system is not placed on the EU market and does not interact with EU individuals, you are generally exempt from the representative requirement. The law targets public or customer-facing AI and output accessible in the EU.
Are there extra fees for multiple AI systems?
REP27 lists a single fee per system; other providers do not publish details. Always confirm with your chosen provider if there are per-system or per-request charges, especially if you operate several AI products.
What documentation must I provide to the representative?
You must provide a technical file describing your AI system, its intended use, and compliance records. The representative holds these for 10 years and makes them available to authorities on request. REP27 manages this as part of its service.
How do I prove compliance to platforms or partners?
REP27 provides a public verification badge and certificate, which can be shown to platforms, app stores, or business partners as proof of compliance with the EU AI Act. Other providers may offer similar documentation—always request confirmation.
What happens if my AI system changes after appointment?
You must update your technical documentation and inform your representative of any significant changes to your AI system or its use in the EU. The representative will update records and, if needed, the mandate. Regular reviews are recommended.
Sources
- EU AI Act: First regulation on artificial intelligence — europarl.europa.eu
- EU AI Act compliance: Article 50 transparency and EU authorised representative | REP27 — gdprrepresentative.com
- Prighter – EU AI Act Authorised Representative — prighter.com
- Engage Compliance – AI Act Representative — engagecompliance.co
- DPO Europe – Authorised Representative under the EU AI Act — data-privacy-office.eu
- The EU AI Act: Ten key things to know — tlt.com
- Auditra: EU AI Act — auditra.eu
- EU AI Act regulatory framework — digital-strategy.ec.europa.eu
- EU AI Act official site — euaiact.com