How to Compare Authorized AI Act Representatives for AI

• Requirement for non-EU AI providers (Art. 22, 50, 54 AI Act)
• Published annual prices: from €290 to €1,677
• Included services: mandate, notifications, AI register, languages
• Appointment timelines: from 24h (REP27) to On request
• Technical compliance and audits not always included
• Fines up to €15 million for non-compliance

Updated 24 October 2026 · 4 sources checked

Providers compared

Prices as published on each provider's website on 24 October 2026, excluding VAT unless stated. Each row links to its source.

Legal Requirements: Key Articles of the AI Act

Regulation (EU) 2024/1689, known as the AI Act, introduces specific obligations for developers, sellers, or distributors of AI systems reaching people in the European Union. The key articles are:

• Article 50: imposes transparency obligations on anyone offering AI systems interacting with people (chatbots, voicebots, generative text/image/audio/video systems). These systems must clearly inform users they are interacting with AI, and generated content must be labeled accordingly in all relevant languages.
• Article 54: requires non-EU providers of generative AI models (general purpose) to appoint an authorized representative in the EU by written mandate.
• Article 22: requires non-EU providers of high-risk AI systems (Annex III) to appoint an EU authorized representative starting December 2, 2027.

The law applies regardless of the company's legal seat: if the AI system reaches EU users, the obligation applies. Main deadlines are:

• August 2, 2026: transparency obligation for systems already on the market (Art. 50).
• December 2, 2027: representative obligation for high-risk systems (Annex III).

Penalties for failure to appoint or ensure transparency can reach €15 million or 3% of global annual turnover. The law distinguishes between providers (who develop or sell AI) and deployers (who use it), but the representative obligation applies only to non-EU providers. Appointment must be formal, with a written mandate and documentation ready for authorities.

How to Choose an AI Representative: Practical Criteria and Service Comparison

Choosing an authorized representative for the AI Act is not just about price. It is essential to evaluate:

• Published and verified price: prefer providers that declare transparent, up-to-date prices. Prices range from €290 to €1,677/year (REP27), €420/year (Prighter), €690/year (Engage Compliance), €950/year (DPO Europe).
• Included services: check if the price includes signed mandate, multilingual notifications, AI register, public badge, request desk, Switzerland assessment. REP27 details every item; other providers do not always specify.
• Appointment timelines: REP27 guarantees designation within 24 hours. Other providers do not always declare timelines.
• Geographic coverage: ensure the service covers all 27 EU states plus Norway, Iceland, and Liechtenstein (EEA). REP27 offers this without extra cost.
• Payment methods: REP27 also allows purchase and invoicing via AWS Marketplace.

Transparency about inclusions and exclusions is crucial: always request a detailed list before signing.

What the Price Really Includes: Beware Hidden Costs and Exclusions

Many providers publish only the base price but do not always clarify what is actually included. Analyzing the offers:

• REP27 clearly specifies: signed mandate with eIDAS, Art. 50 notifications in 8 languages, AI register, public badge, request desk (response within 2 working days), Switzerland assessment (Art. 14 nFADP), verifiable certificate with QR code. Audits, technical tests, or compliance evaluations are not included; if needed, it is stated that other specialists must be engaged.
• DPO Europe, Prighter, Engage Compliance: do not publicly declare what is included in the price. A written detail is necessary to avoid surprises on extra fees, liability limits, or costs for additional requests.

Also watch out for:

• Possible costs for updates, changes, or annual renewals.
• Service limits: representation covers only the AI Act, not GDPR, Digital Services Act, or other regulations, unless explicitly combined offers.
• Obligation to keep documentation updated: with REP27, the register and notifications are managed and archived with a timestamp.

Before choosing, always ask:

• If costs apply for requests from authorities or data subjects.
• If coverage applies to all EU/EEA countries.
• If multilingual notifications and public badge are included.

How Appointment Works: Operational Steps and Required Documentation

The appointment of the AI Act representative follows a standard procedure, but speed and clarity of steps vary among providers. Here is how it works with REP27 and what to ask others:

1. Obligation check: verify if your company is established outside the EU and offers AI (chatbot, generative, high-risk) to people in the Union. REP27 offers a free check to understand if the obligation applies.
2. Plan selection: choose the most suitable plan (AI Transparency, Register + Transparency, AI Act Representative) based on AI type and number of systems managed.
3. Onboarding: provide information on AI systems, target markets, roles (provider/deployer), required languages. On AWS Marketplace, the procedure is integrated and invoicing handled by AWS.
4. Document receipt: receive signed mandate (eIDAS), multilingual notifications ready for publication, AI register, public badge, and verifiable certificate. REP27 guarantees delivery within 24 hours.
5. Publication and maintenance: publish notifications on indicated channels (chat, website, email, video, images), update AI register, and keep all documentation for at least 10 years as required by law.

For other providers, always ask about release timelines, onboarding methods, and details on handling authority requests.

Risks, Fines, and Consequences of Not Appointing a Representative

Failure to appoint an authorized representative entails concrete risks and high penalties:

• Fines up to €15 million or 3% of global annual turnover for violation of transparency or representation obligations (Art. 99 AI Act). For SMEs, the lower amount applies.
• Blocked access to the EU market: authorities can prevent sale or use of non-compliant AI systems.
• Loss of customers: platforms, marketplaces, and large clients already require proof of compliance and presence of notifications and public badges.
• Authority requests: the representative is the contact point for audits, documentation requests, user and authority reports. Failure to respond may worsen penalties.

In case of audit, you must show:

• Signed and valid mandate
• Published and timestamped notifications
• Updated AI register
• Public verification badge or certificate

The representative's responsibility is limited to forwarding requests and maintaining registers: technical compliance and risk assessment remain with the provider.

Decision Matrix: Who Really Needs the Service?

Appointment of an AI Act representative is not mandatory for everyone. Here is a practical decision matrix to understand if you need it:

In summary: the obligation applies only if your AI reaches or interacts with people in the EU.

Operational Checklist for Appointment Today

1. Verify your status: Are you a company established outside the EU? Do you offer AI (chatbot, generative, high-risk) to EU users?
2. Classify your system: Is it generative, high-risk, chatbot, or internal only?
3. Consult the price and service table: Compare providers, inclusions, and exclusions.
4. Request written details: Always ask what is included, timelines, geographic coverage, onboarding methods, and request handling.
5. Complete onboarding: Provide data on AI systems, markets, languages, roles.
6. Receive mandate and notifications: Ensure they are signed, multilingual, and include a public badge.
7. Publish and update: Place notifications where required (chat, website, images, email), update AI register, and keep all for at least 10 years.
8. Check Switzerland assessment: If you have customers in Switzerland, verify if a Swiss representative is also needed (REP27 includes this assessment).

Follow these steps to avoid errors and penalties.

What Providers Usually Don't Say: Limits, Exclusions, and Hidden Risks

• Audits, technical tests, and compliance evaluations are not included (explicitly stated by REP27). If you need these activities, you must engage third parties.
• Response times: only REP27 declares forwarding requests within 2 working days. Other providers do not specify.
• Limited liability: the representative is responsible only for forwarding requests and maintaining registers, not for technical or legal compliance of the AI system.
• Regulatory coverage: AI Act appointment does not cover GDPR, Digital Services Act, or Cyber Resilience Act, unless explicitly combined offers.
• Extra costs: for DPO Europe, Prighter, Engage Compliance, no details are published about extra fees, additional request costs, or updates.
• Multilingual notifications and public badge: only REP27 clearly specifies provision of notifications in 8 languages and verifiable badge.

Always request a written list of inclusions, exclusions, and liability limits before signing.

Three Practical Scenarios: Applicable Obligations and Simplest Path

• US SaaS with chatbot for EU customers: The company offers a SaaS service with chatbot responding to EU customers. Must appoint an AI Act representative (Art. 50, 54), publish multilingual notifications, and keep an AI register. Solution: REP27 AI Act Representative plan, including mandate, notifications, and public badge.
• Chinese Amazon seller with generative AI: Sells products on Amazon using AI that generates descriptions or images visible to EU customers. Must appoint representative and publish notifications (Art. 50). Solution: REP27 AI Transparency plan, verifiable badge, and request desk. If AI is high-risk, full plan is needed.
• UK online store with AI recommendations: UK site uses AI to suggest products to EU customers. If recommendations are visible to the EU public, representative and notifications obligation applies (Art. 50). Solution: Engage Compliance or Prighter for formal representation, or REP27 for multilingual coverage and public badge.

In all cases, provider choice depends on AI type, served markets, required languages, and need for verifiable documentation.