OSTRAI

EU AI ACT AUTHORISED REPRESENTATIVE

EU AI Act Authorised Representative for General-Purpose AI Models

Article 54 representation for providers of general-purpose AI models established outside the European Union that place GPAI models on the Union market.

AI ACT
ARTICLE54GPAI REPRESENTATION

OSTRAI acts as EU AI Act Authorised Representative for eligible providers of general-purpose AI models.

Our service combines Article 54 scope assessment, written appointment, compliance-verification arrangements, technical-documentation infrastructure, AI Office and competent-authority communications, regulatory cooperation and continuing mandate coordination within a specialist European AI and technology-regulation practice.

Check whether Article 54 appliesDiscuss GPAI representation

Not sure whether your model, provider status, market placement or open-source position triggers Article 54? Start with the scope assessment.

ARTICLE 54 / SCOPE

The route to an EU
authorised representative.

  1. Is the entity a provider of a general-purpose AI model?

    A provider is the entity that develops, or has developed, an AI system or GPAI model and places it on the market under its own name or trademark.

    If yes

    If no

    Article 54 does not arise on this basis.

  2. Is the provider established in a third country?

    If yes

    If no

    Article 54 does not arise on the basis of absence of EU establishment.

  3. Is the provider placing the GPAI model on the Union market?

    Commission guidance explains that market placement can arise through routes including APIs, downloads, cloud services and integration into applications.

    If yes

    If no

    No Article 54 representative trigger on this basis.

  4. Does the model meet the Article 54(6) free and open-source conditions?

    If yes

    If no

    EU AI Act Authorised Representative required

  5. Does the GPAI model present systemic risk?

    If yes

    Article 54(6) exemption unavailable.

    If no

    No Article 54 appointment required.

EU AI Act Authorised Representative required

The appointment must be made by written mandate before the model is placed on the Union market.

Request an Article 54 scope assessment

GENERAL-PURPOSE AI MODELS

Article 54 follows
the model provider.

Article 54 is not triggered merely because an organisation operates an AI product or incorporates AI into its services.

The analysis concerns whether the organisation is the provider of a general-purpose AI model.

Provider

The entity developing, or having developed, the model and placing it on the market under its own name or trademark.

GPAI model

An AI model displaying significant generality and capable of competently performing a wide range of distinct tasks, capable of integration into a variety of downstream systems or applications.

Union market

The model is placed on the Union market, meaning its first making available on that market.

The analysis is provider-specific, model-specific and entity-specific.

Assess GPAI provider status

TWO REGULATORY OBJECTS

Model representation
is not system representation.

ARTICLE 54

General-Purpose
AI Model

  • Provider established outside the Union
  • GPAI model placed on the Union market
  • Annex XI technical documentation
  • Article 53 obligations
  • Article 55 obligations where systemic risk applies
  • AI Office / competent-authority interface

ARTICLE 22

High-Risk
AI System

  • Provider established outside the Union
  • High-risk AI system made available on the Union market
  • Conformity documentation
  • EU declaration of conformity
  • Conformity-assessment interface
  • Registration obligations where applicable
  • Competent-authority interface

A GPAI model and an AI system are distinct regulatory objects under the AI Act. An organisation's Article 54 position should therefore not be assumed to determine its Article 22 position.

High-Risk AI System Representation

FREE & OPEN SOURCE

Open-source status can change the representative requirement.

Article 54(6) contains a specific exemption from the representative obligation.

Assess the open-source exemption

  • Free and open-source licence

    Allows access, usage, modification and distribution.

  • Model parameters publicly available

    Including weights.

  • Architecture information publicly available

  • Model-usage information publicly available

SYSTEMIC-RISK CARVE-OUT

The Article 54(6) exemption does not apply where the general-purpose AI model presents systemic risk.

ALL RELEVANT ARTICLE 54(6) CONDITIONS MET

Article 54 representative requirement does not apply.

Article 53 and Article 54 do not use the open-source exemption in exactly the same way.

ARTICLE 53(2)

Specified documentation obligations

For qualifying free and open-source GPAI models, the exemption concerns the obligations in Article 53(1)(a) and (b):

  • Technical documentation for authorities
  • Information and documentation for downstream providers

It does not remove:

  • The copyright-policy obligation under Article 53(1)(c)
  • The training-content-summary obligation under Article 53(1)(d)

And it does not apply to GPAI models with systemic risk.

ARTICLE 54(6)

The representative appointment

A qualifying free and open-source model can remove the requirement to appoint an authorised representative.

Again, the exemption does not apply where the GPAI model presents systemic risk.

Open-source analysis therefore requires separate consideration of the provider's Article 53 obligations and Article 54 representative position.

PROVIDER OBLIGATIONS

The representative mandate sits
on top of Article 53 compliance.

ARTICLE 53(1)(a)

Technical documentation

Draw up and keep up-to-date technical documentation of the GPAI model, including its training and testing process and model evaluation, containing at least the information required by Annex XI.

ARTICLE 53(1)(b)

Downstream-provider information

Prepare and maintain information enabling downstream AI-system providers to understand the capabilities and limitations of the GPAI model and comply with their own AI Act obligations.

ARTICLE 53(1)(c)

Copyright policy

Maintain a policy to comply with Union copyright and related-rights law, including identifying and respecting relevant rights reservations.

ARTICLE 53(1)(d)

Training-content summary

Prepare and make publicly available a sufficiently detailed summary of the content used for training the model.

ARTICLE 54 / VERIFICATIONArticle 54 requires the authorised representative to verify that the technical documentation specified in Annex XI has been drawn up and that the obligations referred to in Article 53 and, where applicable, Article 55 have been fulfilled.

ARTICLE 55

Systemic risk changes
the compliance architecture.

ARTICLE53

GPAI provider obligations

ARTICLE54

EU authorised representative

ARTICLE / WHERE APPLICABLE55

Systemic-risk obligations

Explore AI Act Advisory

ARTICLE 54 MANDATE

The authorised representative is part of the GPAI compliance architecture.

Article 54 does not establish a passive address service. The written mandate must empower the representative to verify specified provider obligations, maintain regulatory documentation, respond to reasoned information requests and cooperate with the AI Office and competent authorities.

Verify

The technical documentation specified in Annex XI has been drawn up and Article 53 and, where applicable, Article 55 obligations have been fulfilled.

Retain

Keep a copy of the technical documentation specified in Annex XI and provider contact details available for 10 years after market placement.

Respond

Provide information and documentation necessary to demonstrate Chapter V compliance following a reasoned AI Office request.

Cooperate

Cooperate with the AI Office and competent authorities concerning the GPAI model, including where it is integrated into AI systems placed on the Union market.

REGULATORY INTERFACE

AI Office, representative
and provider.

AI Office / competent authorities

OSTRAI

EU AI ACT AUTHORISED REPRESENTATIVE

  • Regulatory contact
  • Mandate interface
  • Documentation interface
  • Information requests
  • Regulatory cooperation
  • Escalation
  • Mandate coordination

Represented GPAI provider

  • Model development
  • Article 53 compliance
  • Annex XI documentation
  • Downstream documentation
  • Copyright policy
  • Training-content summary
  • Article 55 compliance where applicable
  • Technical and organisational implementation

The mandate must allow the AI Office or competent authorities to address OSTRAI in addition to or instead of the provider on issues concerning AI Act compliance.

YOUR REPRESENTATION SERVICE

A functioning Article 54
representation structure.

Formal Article 54 appointment

Written appointment of OSTRAI Limited as EU AI Act Authorised Representative within the agreed mandate.

Article 53 / 55 verification structure

A structured process enabling OSTRAI to verify that the relevant Article 53 obligations and, where applicable, Article 55 obligations have been fulfilled.

Annex XI documentation arrangements

Secure arrangements for OSTRAI to hold the copy of the technical documentation specified in Annex XI required by Article 54.

Designated regulatory channel

A monitored OSTRAI channel for communications relating to the representative mandate.

Designated lead

A defined OSTRAI contact coordinating the representative relationship and material regulatory escalations.

AI Office communications

Receipt and coordination of communications addressed to OSTRAI in its Article 54 capacity.

Competent-authority cooperation

Cooperation with relevant authorities within the statutory representative role.

Information-request coordination

Coordination of reasoned requests for information and documentation necessary to demonstrate Chapter V compliance.

Escalation protocol

Defined contacts and procedures for urgent, material or time-sensitive regulatory matters.

Mandate maintenance

Review of material changes affecting the represented provider, relevant models, market-placement position and representative mandate.

Discuss the Article 54 mandate

ANNEX XI

The representative must remain connected to the evidence behind the model.

Article 54 requires the authorised representative to keep a copy of the technical documentation specified in Annex XI at the disposal of the AI Office and national competent authorities for 10 years after the general-purpose AI model has been placed on the market.

The representative's documentation structure depends on accurate and current information being supplied by the provider.

  1. Provider develops / updates Annex XI documentation
  2. OSTRAI verification
  3. OSTRAI documentation copy
  4. 10-year availability
  5. AI Office / competent-authority request
  6. Information and evidence coordination

MODEL DOCUMENTATION

The documentation
must remain current.

Article 53 requires the provider to draw up and keep up-to-date model technical documentation.

The Transparency Chapter of the GPAI Code similarly describes maintaining model documentation, updating it to reflect relevant changes and retaining prior versions for the relevant period.

  • Model architecture
  • Training process
  • Testing
  • Evaluation
  • Model versions
  • Capabilities & limitations
  • Downstream information
  • Relevant updates
Discuss representation readiness

RESPONSIBILITY

The provider remains responsible for the model and its underlying compliance.

Representation and substantive AI Act implementation are distinct.

Represented GPAI provider

  • Article 53 compliance
  • Model documentation
  • Downstream-provider information
  • Copyright policy
  • Training-content summary
  • Systemic-risk compliance where applicable
  • Model governance
  • Technical implementation
  • Security
  • Model evaluation

OSTRAI

ARTICLE 54 AUTHORISED REPRESENTATIVE

  • Verification
  • Documentation custody
  • Regulatory interface
  • Information-request coordination
  • Cooperation
  • Escalation
  • Mandate maintenance

ARTICLE 54(5)

The mandate cannot continue regardless of provider conduct.

Where the authorised representative considers, or has reason to consider, that the provider is acting contrary to its obligations under the AI Act, Article 54 requires the representative to terminate the mandate. The representative must also immediately inform the AI Office of the termination and the reasons for it.

This statutory duty is one reason OSTRAI applies controlled acceptance, compliance-readiness review and ongoing mandate monitoring.

  1. Potential compliance concern identified
  2. Obtain information / clarification
  3. Assess Article 54(5) position
  4. IF ARTICLE 54(5) THRESHOLD IS MET
  5. Terminate mandate
  6. Immediately inform AI Office

CONTROLLED ACCEPTANCE

We assess the mandate
before appointment.

Before accepting an Article 54 mandate, OSTRAI reviews the provider, relevant GPAI model or models, provider status, EU market-placement position, open-source status where relevant, Article 53 compliance structure, technical documentation specified in Annex XI, systemic-risk position where relevant, Article 55 arrangements where applicable, regulatory history and operational readiness.

Where classification, provider status, Article 53 implementation, systemic-risk assessment or underlying documentation requires substantive legal, regulatory or technical work, that work can be separately scoped before appointment.

The provider's regulatory position and readiness determine whether OSTRAI can accept the mandate.

Discuss whether OSTRAI can accept the mandate

ONBOARDING

The information behind
an effective Article 54 appointment.

Entity
Correct legal entity to be represented.
Provider status
Basis on which the entity is the GPAI-model provider.
EU establishment
Whether the relevant provider has an establishment in the Union.
GPAI model
Relevant model or models.
Model versions
Versions relevant to market placement and documentation.
Union market placement
How and when the model is placed on the Union market.
Distribution route
API · download · cloud service · integrated distribution · other.
Open-source position
Licence, weights, architecture and model-use information where relevant.
Article 53 compliance
Status of each applicable Article 53 obligation.
Annex XI documentation
Availability, version and ownership.
Downstream-provider documentation
Relevant Annex XII / Article 53(1)(b) information.
Copyright-policy position
Article 53(1)(c).
Training-content summary
Article 53(1)(d).
Systemic-risk position
Article 51 / 52 assessment where relevant.
Article 55
Relevant arrangements where systemic risk applies.
Regulatory history
Existing AI Office, Commission or competent-authority communications.
Internal contacts
Legal · regulatory · model / engineering · security · copyright · compliance.
Escalation
Named contacts for urgent or material regulatory matters.
Start GPAI Representative onboarding

OPERATIONAL READINESS

The representative needs access to the organisation behind the mandate.

Effective Article 54 representation depends on OSTRAI being able to obtain accurate, current information, evidence and instructions when regulatory issues arise.

  • Legal / regulatory
  • AI governance
  • Model engineering
  • Model documentation
  • Copyright
  • Safety / risk
  • Cybersecurity
  • Product
  • Executive escalation
  • External technical advisers where relevant

OSTRAIARTICLE 54 REPRESENTATIVE

SCOPE

Representation and
AI Act implementation are distinct.

Standard representative mandate

  • Written Article 54 appointment
  • Representative regulatory channel
  • Article 53 / 55 verification arrangements
  • Annex XI documentation custody
  • AI Office communications
  • Competent-authority communications
  • Routine cooperation
  • Information-request coordination
  • Escalation
  • Mandate maintenance

Separately scoped support

  • GPAI model classification
  • Provider-status assessment
  • Market-placement analysis
  • Open-source analysis
  • Article 53 gap assessment
  • Annex XI documentation development or remediation
  • Annex XII / downstream documentation
  • Copyright-policy implementation
  • Training-content-summary support
  • Systemic-risk assessment
  • Article 51 / 52 analysis
  • Article 55 compliance
  • Code of Practice implementation
  • Model-governance support
  • AI Act contractual allocation
  • Regulatory-response work
Explore AI Act Advisory

GPAI CODE OF PRACTICE

The Code can support the
provider's compliance architecture.

Providers may use the GPAI Code of Practice as a means of demonstrating compliance with relevant Article 53 and Article 55 obligations. Adherence to the Code does not itself constitute conclusive evidence of compliance.

Transparency

Documentation corresponding to Article 53(1)(a) and (b), Annex XI and Annex XII.

Copyright

Article 53(1)(c) copyright-policy implementation.

Safety & Security

Article 55 systemic-risk compliance for GPAI models with systemic risk.

Code-of-Practice implementation is substantive compliance work and is separately scoped from the standard representative mandate.

CURRENT LAW

The GPAI regime
is already operational.

  1. GPAI-provider obligations entered into application.

  2. Commission enforcement of the applicable GPAI obligations operates fully, including the fines framework referred to in Commission guidance.

  3. Providers of GPAI models placed on the market before 2 August 2025 must comply by this date.

For newly placed models within scope, the Article 54 appointment must be made before Union market placement.

AI REGULATION PRACTICE

Representation backed by substantive AI regulatory capability.

OSTRAI's Article 54 Authorised Representative service sits within a broader European AI and technology-regulation practice.

Where necessary, separately scoped work can address model classification, provider status, market placement, Article 53 compliance, technical documentation, copyright, systemic risk, Article 55 obligations, cybersecurity, downstream-provider requirements, contractual allocation and regulatory response.

This allows communications reaching the authorised representative to be understood within their wider legal, technical and regulatory context.

AI Act AdvisoryDigital RegulationPrivacy & DataCybersecurityStandards & Standardisation

WHY OSTRAI

Why OSTRAI for Article 54 representation

Article 54 focus

Representation structured around the statutory authorised-representative role.

Compliance-verification structure

A mandate model designed around Article 54's requirement to verify relevant Article 53 and Article 55 compliance.

Documentation readiness

Infrastructure around Annex XI documentation and regulatory information requests.

Defined escalation

Clear routes for AI Office and competent-authority communications.

Cross-regulatory capability

Ability to identify intersections with privacy, cybersecurity, copyright, product regulation and digital regulation.

Standards perspective

Ability to identify where harmonised standards, common specifications or relevant technical standards interact with GPAI compliance.

QUESTIONS & ANSWERS

Before
appointment.

Article 54 applies to a provider established in a third country that places a general-purpose AI model on the Union market, unless the Article 54(6) free and open-source exemption applies. The representative must be established in the Union and appointed by written mandate before market placement, subject to the transitional arrangements for models already on the market before 2 August 2025.

No. The analysis depends on whether the organisation is the provider of a GPAI model and places that model on the Union market. Using AI or incorporating a model into a service does not, by itself, establish an Article 54 requirement.

A GPAI model has significant generality, can competently perform a wide range of distinct tasks and can be integrated into a variety of downstream systems or applications. Article 3(63) excludes models used for research, development or prototyping before they are placed on the market. The model and its actual capabilities must be assessed.

It means the first making available of the model on the Union market. Commission guidance explains that this can occur through APIs, downloads, cloud services, integration into applications and other distribution routes. The assessment concerns the actual model, provider and distribution arrangements.

Potentially, yes, where the Article 54 conditions are met and no exemption applies. Nationality itself is not the test: establishment, GPAI-provider status and Union market placement matter.

Potentially. Article 54(6) requires a free and open-source licence allowing access, usage, modification and distribution, with model parameters including weights, architecture information and model-usage information publicly available. The exemption does not apply to GPAI models with systemic risk.

No. For qualifying models, Article 53(2) concerns the documentation obligations in Article 53(1)(a) and (b). The copyright-policy and training-content-summary obligations remain applicable. The exemption does not apply to GPAI models with systemic risk.

The representative verifies that the technical documentation specified in Annex XI has been drawn up and that the provider has fulfilled the relevant Article 53 obligations and, where applicable, Article 55 obligations. Verification is not certification and does not transfer the provider’s underlying compliance responsibilities.

Article 54 requires the representative to keep a copy of the technical documentation specified in Annex XI and the provider’s contact details available for 10 years after the GPAI model has been placed on the market.

Yes. The mandate must allow the AI Office or competent authorities to address the authorised representative in addition to or instead of the provider on issues related to AI Act compliance.

Article 54(5) requires the representative to terminate the mandate if it considers, or has reason to consider, that the provider is acting contrary to its obligations under the AI Act. It must immediately inform the AI Office of the termination and the reasons for it.

Article 55 obligations apply in addition to the applicable Article 53 obligations and Article 54 representative requirements. The free and open-source exemptions in Articles 53(2) and 54(6) do not apply to GPAI models with systemic risk.

Yes. AI Act advisory and implementation work can be separately scoped, including documentation, compliance gaps and systemic-risk arrangements. This is distinct from the standard Article 54 representative mandate.

No. Article 54 concerns providers of GPAI models. Article 22 concerns providers of high-risk AI systems. They are separate statutory representative regimes and require separate assessment.

EU AI ACT AUTHORISED REPRESENTATIVE

Put the right Article 54
representation structure in place.

OSTRAI supports eligible providers of general-purpose AI models established outside the European Union from Article 54 scope and provider assessment through onboarding, written appointment, compliance-verification arrangements, infrastructure for the technical documentation specified in Annex XI, AI Office interface, regulatory cooperation and continuing representation.

Check whether Article 54 appliesDiscuss GPAI representation