提供者
You develop or have an AI system developed and place it on the market or put it into service under your name or trademark.
AI Act实务指南
面向向欧盟客户提供AI系统或AI赋能服务的提供者、SaaS公司、模型部署方、平台以及非欧盟团队的实用导向页面。
Start here
The EU AI Act applies differently depending on whether you are the provider of an AI system, a deployer using it in your organisation, an importer, a distributor, a product manufacturer, or a general-purpose AI model provider. A company selling AI services in the EU can hold more than one role in practice.
For lead qualification, the important first step is to identify who controls the AI system, who places it on the EU market, who makes substantial modifications and who is named toward EU customers.
1. Identify your EU AI Act role
You develop or have an AI system developed and place it on the market or put it into service under your name or trademark.
You use an AI system under your authority in a professional context, for example in HR, education, credit or customer decision workflows.
You make a third-country AI system available in the EU supply chain and may have checks before offering it to customers.
2. Screen whether the system is high-risk
Many AI services are not high-risk. But if your system is used in areas such as employment, education, essential private or public services, biometrics, migration, law enforcement or justice, you should perform a structured Annex III screening.
Recruitment, candidate ranking, employee monitoring, performance evaluation and work allocation tools can raise high-risk questions.
Admission, assessment, access to education or training and student evaluation use cases need careful classification.
Credit, insurance, access to public benefits, emergency services and similar decisions may require a stricter route.
3. Build the evidence file early
EU customers often ask AI vendors for documentation earlier than the legal deadline because procurement, risk management and supplier onboarding already need answers. Prepare a practical evidence package before enterprise sales conversations.
What the AI system does, intended users, intended purpose, EU customer types and supported decisions.
Why the system is or is not high-risk, including Annex III reasoning and product-regulation links where relevant.
Who owns compliance, incident handling, customer communication and regulatory responses.
4. Know when an EU authorised representative becomes relevant
If the provider is established outside the EU and provides a high-risk AI system into the Union, Article 22 may require an authorised representative established in the EU. The AR is appointed by written mandate and acts as the EU point of contact for competent authorities.
| Question | Why it matters |
|---|---|
| Is the provider established outside the EU? | Article 22 targets third-country providers of high-risk systems entering the Union market. |
| Is the AI system high-risk? | Representative obligations are tied to high-risk AI systems, not every AI tool. |
| Will the system be placed on the market or put into service in the EU? | The EU market route determines whether an EU representative contact point is needed. |
5. Understand timing
For Annex III high-risk AI systems, core Chapter III obligations are expected to apply from 2 December 2027 after Regulation (EU) 2026/1744. That date is not a reason to wait. Classification, documentation, customer evidence, governance and representative planning take time.
Map AI systems, EU customers, intended use and provider/deployer roles.
Prepare risk classification and a concise evidence pack for EU buyers.
Confirm whether a high-risk route, conformity evidence and 第22条授权代表 are needed.
Maintain records, monitoring, incident workflows and authority response channels.
Practical checklist
常见问题
No. The Article 22 representative route is primarily relevant for non-EU providers of high-risk AI systems.
Yes, if the company places the AI system on the market or puts it into service under its name or trademark. The details matter.
General-purpose AI models have separate obligations and may involve different representative triggers. This guide focuses on AI systems and high-risk market access triage.
Prepare a concise classification note, role analysis, documentation status and responsible contact. If you are a non-EU high-risk provider, also confirm the Article 22 representative route.
Tell us where the provider is established, what the AI system does, and whether Annex III may apply. We will qualify whether an Article 22 representative discussion is relevant.