A side-by-side comparison of Authorised Representative and Importer. Understand how a mandated EU representative differs from the actor that places a non-EU provider's AI system on the EU market.
Authorised Representative identifies a regulated AI supply-chain role under the EU AI Act and related governance obligations.
Context: Most relevant when a non-EU provider needs an EU-based representative for specified regulatory procedures.
Importer identifies a regulated AI supply-chain role under the EU AI Act and related governance obligations.
Context: Most relevant when an EU entity brings a non-EU provider's AI system into the EU market.
| Aspect | Authorised Representative | Importer |
|---|---|---|
| Legal role | A mandated EU-based person or organization acting on behalf of a provider for specified obligations. | An EU-based person or organization that places a non-EU provider's branded AI system on the EU market. |
| Lifecycle position | Connected to representation and procedural compliance for a provider before or during market access. | Connected to the act of placing a third-country provider's system on the EU market. |
| Main obligations | Performs obligations and procedures accepted in the written mandate. | May carry specific compliance obligations tied to the imported AI system. |
| Documentation duties | Documentation duties should reflect the mandate and the provider obligations it covers. | Documentation duties should support evidence that the imported system can lawfully be made available in the EU. |
| Common mistake | Treating a representative as the market actor responsible for import whenever it has an EU address. | Treating an importer as merely a contact point, even though the role is tied to market placement. |
In practice, teams should map both the mandate chain and the market-entry chain, because the same commercial relationship can involve different legal actors and different evidence duties.
Using Authorised Representative as a generic synonym for any EU contact person.
Calling every reseller or EU affiliate an Importer without checking whether it places a non-EU branded system on the market.
Leaving the written mandate undocumented or too vague for audit purposes.
Use Authorised Representative when discussing an EU-established person or body that has accepted a written mandate from a provider. The term is best for role mapping, mandate records, and procedures performed on the provider's behalf.
Use Importer when the focus is the EU actor placing an AI system on the EU market under the name or trademark of a person established outside the Union. The term is best for supply-chain mapping, market-entry checks, and contractual responsibility allocation.
No. An authorised representative acts under a written mandate from a provider, while an importer places a non-EU provider's AI system on the EU market.
A single organization may hold multiple roles if the facts support them, but the roles should still be documented separately. The mandate-based role and the market-placement role answer different compliance questions.
It helps identify who provides evidence, who has accepted delegated procedures, and who is responsible for market-entry compliance under EU AI Act workflows.
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