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AI Act Services Agreement

Europe Services, SE — version 1.1, 26 September 2026. This is the agreement referred to in the AI Act designation form and in every AI Act mandate letter issued under the codes AI27-. It applies to the plans AI Transparency, AI Register + Transparency and AI Act Representative. It does not replace the EU Representative Services Agreement, which continues to govern GDPR, UK GDPR and GPSR designations.

1. Parties

The provider is Europe Services, SE, Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic, IČO 03571785, DIČ CZ03571785, registered at the Municipal Court in Prague, file H 1486 (“we”, “us”). The client is the company named in the designation form (“the client”), acting as provider or deployer of AI systems, or as provider of general-purpose AI models, within the meaning of Regulation (EU) 2024/1689 laying down harmonised rules on artificial intelligence (“the AI Act”), as amended.

2. Business customers only

These services are offered only to businesses, public bodies and other professional users acting for purposes of their trade, business or profession. By signing the form the client confirms that it is not a consumer. Consumer rights of withdrawal therefore do not apply; the refund rules in clause 14 apply instead.

3. Definitions

Terms such as AI system, general-purpose AI model, general-purpose AI model with systemic risk, provider, deployer, authorised representative, AI Office, national competent authority, market surveillance authority, notified body, high-risk AI system, deep fake and placing on the market have the meaning given in Article 3 of the AI Act. “Mandate” means the written designation signed by the client in the form and countersigned by us. “Declared systems” means the AI systems and models the client lists in the form, as updated under clause 9. “Notices” means the transparency texts supplied under clause 5. “Working day” means a day other than a Saturday, Sunday or public holiday in the Czech Republic.

4. The three plans

AI Transparency (Article 50). For companies whose AI systems interact with natural persons or generate or manipulate content. We supply and maintain the notices required by Article 50 of the AI Act for the declared systems, the public badge and the verification page, and we answer questions about the notices from users and authorities.

AI Register + Transparency. Everything in AI Transparency, plus a register of the declared systems: what each system does, its supplier, whether the client is provider or deployer, where people meet it, whether it may fall within Annex III, which notice applies and when it was last reviewed.

AI Act Representative (Articles 22 and 54). For providers established in a third country that place a general-purpose AI model or a high-risk AI system on the Union market. The client appoints us as its authorised representative by written mandate. The fee is per general-purpose AI model or per high-risk AI system, as stated in the order. The scope of each plan is set out in Annex 2.

5. What we do — transparency (all plans)

Within five working days of the approved form we deliver, in English and in up to seven further languages chosen by the client among Italian, Spanish, French, German, Portuguese, Dutch and Polish:

  1. the notice informing natural persons that they are interacting with an AI system (Article 50(1)), for chat, voice and email interfaces;
  2. guidance on the machine-readable marking of synthetic audio, image, video and text content that Article 50(2) requires of providers of generative systems, together with the visible label the client may use;
  3. the notice for emotion recognition or biometric categorisation systems (Article 50(3)), where the client declares one;
  4. the disclosure for deep fakes and for AI-generated or manipulated text published to inform the public on matters of public interest (Article 50(4)), taking account of the exceptions the Article provides for evidently artistic, creative, satirical or fictional works and for text subject to human review and editorial responsibility;
  5. placement instructions so that the information is given in a clear and distinguishable manner at the latest at the first interaction or exposure, and in a form that respects the applicable accessibility requirements (Article 50(5)).

We publish the verification page and the badge under the client’s AI27- code, and keep every version of every notice with its date of issue. When a user or an authority writes to us about the notices, we log the date of arrival and forward the message to the client within two working days, or answer it ourselves where the answer is only a description of the notices already published. We do not implement technical marking in the client’s systems; that remains the provider’s task.

6. What we do — authorised representative (AI Act Representative plan)

The mandate empowers us to be addressed, in addition to or instead of the client, by the AI Office and the competent authorities on all issues related to ensuring compliance with the AI Act for the model or system concerned. Within the limits of the mandate we perform the following tasks.

For a high-risk AI system (Article 22): (a) verify that the EU declaration of conformity and the technical documentation have been drawn up and that an appropriate conformity assessment procedure has been carried out by the client; (b) keep at the disposal of the competent authorities and national authorities or bodies, for a period of ten years after the system has been placed on the market or put into service, the contact details of the client, a copy of the EU declaration of conformity, the technical documentation and, where applicable, the certificate issued by the notified body; (c) provide a competent authority, upon a reasoned request, with all the information and documentation necessary to demonstrate conformity, including access to the logs automatically generated by the system to the extent they are under the client’s control; (d) cooperate with competent authorities, upon a reasoned request, in any action they take in relation to the system, in particular to reduce and mitigate its risks; (e) where applicable, comply with the registration obligations in Article 49(1), or, where the registration is carried out by the client, ensure that the information referred to in Annex VIII, Section A, point 3 is correct.

For a general-purpose AI model (Article 54): (a) verify that the technical documentation specified in Annex XI has been drawn up and that all obligations referred to in Article 53 and, where applicable, Article 55 have been fulfilled by the client; (b) keep a copy of the technical documentation at the disposal of the AI Office and the national competent authorities for a period of ten years after the model has been placed on the market, together with the contact details of the client; (c) provide the AI Office, upon a reasoned request, with all the information and documentation necessary to demonstrate compliance; (d) cooperate with the AI Office and the competent authorities, upon a reasoned request, in any action they take in relation to the model, including when it is integrated into AI systems placed on the market or put into service in the Union. Under Article 54(6), no representative is required for models released under a free and open-source licence that do not present systemic risk; we tell the client if that exemption applies.

Our tasks are performed on the basis of the documents the client provides. Verification means checking that the required documents exist, are complete in form and match the declared model or system; it is not a technical audit or a conformity assessment.

7. What we do not do

We do not develop, train, test, audit, evaluate, classify or certify AI systems or models. We do not carry out conformity assessments, fundamental rights impact assessments under Article 27, data protection impact assessments or model evaluations under Article 55, and we are not a notified body. We do not perform the deployer obligations of Article 26 on the client’s behalf. We do not give legal advice on whether a system is high-risk or prohibited: the classification is the client’s decision and responsibility, and the form records it. We do not answer, on the client’s behalf, questions about the substance of an AI system’s outputs or decisions. Compliance with the AI Act remains at all times the obligation of the client as provider or deployer.

8. Documents and access the client must provide

The client shall enable us to perform the tasks of the mandate (Articles 22(2) and 54(2)). In particular, before the AI Act Representative mandate starts and throughout its term, the client shall provide in English, and keep up to date: the technical documentation (Annex IV for high-risk systems, Annex XI for general-purpose models), the EU declaration of conformity and any notified-body certificate where applicable, the instructions for use, the public summary of training content and the copyright policy for general-purpose models, and a technical contact able to answer authorities within the deadlines they set. The mandate is not countersigned until these documents are received.

9. What the client undertakes

The client undertakes to: (a) declare truthfully every AI system or model in scope, its role and where people meet it; (b) inform us within ten working days of any new system, substantial modification, serious incident, corrective action, withdrawal from the market or change of classification; (c) publish the notices where we indicate and keep them visible and unaltered, or tell us before changing them; (d) answer our questions and those of the authorities within the deadlines we pass on; (e) not use our name, badge or code for any system not declared in the form; (f) keep us informed of any investigation, request or measure by an authority concerning a declared system.

10. Termination of the mandate by the representative

As required by Articles 22(4) and 54(5) of the AI Act, if we consider or have reason to consider that the client is acting contrary to its obligations under the AI Act, we will terminate the mandate. In that case we will immediately inform the relevant market surveillance authority and, where applicable, the relevant notified body (for high-risk systems) or the AI Office (for general-purpose AI models) of the termination and of the reasons for it. The fee for the current period is not refunded.

11. Prohibited practices and excluded systems

We do not accept, and the client declares that it does not operate, any AI practice prohibited by Article 5 of the AI Act, nor any activity listed in Annex 3. If we learn that a declared system falls within Article 5, clause 10 applies.

12. Fees, currencies and taxes

Fees are stated in euro and paid in advance for twelve months, or in twelve monthly instalments where offered. The AI Act Representative fee is per general-purpose AI model or per high-risk AI system. Clients may pay in USD, GBP, CAD, AUD, NZD, CHF, CZK, JPY or NOK: the amount charged is the euro fee converted at the most recent euro reference rate published by the European Central Bank at the time of payment. The contract price remains the euro amount; invoices show both. Renewals are charged in the same currency as the first payment, converted from the euro renewal fee at the most recent ECB reference rate published before each renewal; refunds are made in the currency of the original payment. Fees are exclusive of VAT. Clients established in the Union with a valid VAT number are invoiced under the reverse-charge mechanism; clients outside the Union are invoiced without VAT; Czech VAT is added where the law requires it. Payments are processed by Mollie B.V.; we do not store card data.

13. Term, renewal, price changes and cancellation

The mandate runs for twelve months from approval and renews automatically for further twelve-month periods at the renewal fee then in force, unless the client cancels before the renewal date from its account area or by email. We may change renewal fees by giving at least thirty days’ notice before the renewal date; the client may then cancel without charge. Monthly instalment plans can be cancelled with effect from the end of the current twelve-month period. For the AI Act Representative plan, the ten-year retention duty under Articles 22 and 54 survives the end of the service for the documents we already hold; the client may instead ask us in writing to hand them to a successor representative it names, after which our retention duty ends. When the mandate ends for any reason, we inform the AI Office or the competent authority that we no longer act as authorised representative.

14. Refunds

If we decline the form, for example because a declared system falls within Annex 3 or the documents in clause 8 are not provided within thirty days, we refund the fee in full. Once the mandate has been countersigned or the notices delivered, fees are not refundable, except where we materially fail to perform and do not remedy the failure within fifteen working days of written notice, in which case we refund the unused portion.

15. Suspension for non-payment

If a renewal payment fails, we give fourteen days’ grace. After that the verification page shows the mandate as suspended and the badge stops confirming it. A suspension that lasts thirty days ends the mandate under clause 13.

16. Intellectual property

The notices written for the client may be used, copied and translated by the client for its declared systems during the mandate and afterwards. Our templates, methods, register format and verification pages remain our property. The client keeps all rights in its AI systems, models and documentation; it grants us only the right to use them to perform the mandate.

17. Liability

Our total liability in any twelve-month period is limited to the fees paid by the client in that period for the plan concerned. We are not liable for indirect or consequential loss, loss of profit or loss of data, nor for fines, measures or damages arising from the client’s AI systems or models, from their classification, from information or documents the client supplied, or from the client’s failure to publish the notices. Nothing in this clause limits liability for intent or gross negligence, or any other liability that cannot be limited under Czech law.

18. Indemnity

The client indemnifies us against claims, fines and reasonable costs brought against us as its authorised representative or as the holder of its notices, to the extent they arise from the client’s AI systems or models, from inaccurate or incomplete information or documents, or from a breach of clauses 8, 9 or 11.

19. Confidentiality and personal data

We keep the technical documentation and every document the client provides confidential, and disclose it only to the AI Office, the competent authorities or a notified body where the AI Act requires, to a court, or to a successor representative on the client’s instruction. We are controller of the account and billing data of the client’s contacts, as described in our privacy notice. Where we process personal data on the client’s behalf, the Data Processing Agreement published with the EU Representative Services Agreement applies.

20. Public verification page and register

The verification page is public and shows the client’s name, the plan, the legal basis and the validity of the mandate. With the client’s consent given in the form, the client is also listed in our public register of represented companies; the consent can be withdrawn at any time.

21. Changes in the law and to this agreement

The AI Act applies in stages and has been amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI). Where the law, delegated or implementing acts, harmonised standards, codes of practice or guidance of the AI Office change what a notice or a mandate must contain, we update the notices and the service at no extra cost for the current period and tell the client what changed. We may amend this agreement for future periods by publishing a new version and notifying the client at least thirty days before its next renewal.

22. Subcontractors, assignment and force majeure

We may use subcontractors for translation, hosting and payment processing, and remain responsible for them. The authorised-representative tasks are not subcontracted. Neither party may assign this agreement without the other’s written consent, except to a successor of its whole business. Neither party is liable for delay caused by events beyond its reasonable control, provided it informs the other promptly and resumes performance as soon as possible.

23. Sanctions

We do not act for persons subject to EU restrictive measures, nor for AI systems or models whose supply into the Union would breach them.

24. Notices between the parties

Notices are given by email: to us at info@gdprrepresentative.com, to the client at the contact address in the form. A notice is received on the working day after it is sent.

25. Order of precedence, entire agreement and severability

The signed mandate letter, this agreement and its annexes form the whole agreement for the AI Act plans and replace any prior discussion. If they conflict, the mandate letter prevails, then this agreement, then the annexes. If any provision is held invalid, the rest remains in force and the invalid provision is replaced by a valid one closest to its purpose. Clauses 6(b), 13, 17, 18 and 19 survive the end of the agreement.

26. Electronic signature

The client signs the mandate electronically in the form; we countersign on approval. Both signatures are recorded with their date and IP address and are valid under Regulation (EU) No 910/2014 (eIDAS).

27. Governing law and jurisdiction

This agreement is governed by the law of the Czech Republic, excluding the United Nations Convention on Contracts for the International Sale of Goods. The courts of Prague have exclusive jurisdiction.

Annex 1 — Service levels

  1. Form reviewed within two working days of receipt.
  2. Notices delivered within five working days of the approved form; updates within five working days of a declared change.
  3. Messages from users and authorities logged the day they arrive and forwarded within two working days.
  4. Reasoned requests from the AI Office or a competent authority (AI Act Representative plan): acknowledged within one working day and forwarded to the client the same day; documents we already hold supplied within the deadline the authority sets.
  5. Verification page updated within one working day of any change of status.

Annex 2 — Scope of each plan

  1. AI Transparency: notices under Article 50 for up to three declared AI systems or interfaces; up to eight languages; badge; verification page; dated record of versions; handling of messages about the notices.
  2. AI Register + Transparency: everything above for up to fifteen declared systems, plus the register, reviewed at each declared change and at least once a year.
  3. AI Act Representative: written mandate under Articles 22 and 54 for one general-purpose AI model or one high-risk AI system; the tasks in clause 6; ten-year retention; handling of requests from the AI Office and competent authorities; certificate with AI27- code and badge; the transparency service for the same model or system.
  4. More systems, models or languages than stated above are quoted in writing before any work starts.

Annex 3 — Excluded activities

  1. any practice prohibited by Article 5 of the AI Act, including manipulative or deceptive techniques, exploitation of vulnerabilities, social scoring, individual criminal-risk prediction based solely on profiling, untargeted scraping of facial images, emotion recognition in the workplace or in education institutions, biometric categorisation inferring sensitive characteristics, and real-time remote biometric identification in publicly accessible spaces for law enforcement;
  2. AI systems placed on the market, put into service or used exclusively for military, defence or national security purposes;
  3. AI systems whose main purpose is the processing of special categories of personal data under Article 9 GDPR or data relating to criminal convictions under Article 10 GDPR;
  4. AI systems aimed primarily at children under 16;
  5. adult content, gambling, crypto-assets, weapons, and medicines sold to consumers;
  6. any activity that requires a licence the client does not hold.

Questions on this agreement: info@gdprrepresentative.com