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Regulation Tracker / EU AI Act / Chapter III · Section 3

Article 23
Obligations of importers

Chapter III — Classification rules for high-risk AI systems, Section 3 — Obligations of providers of high-risk AI systems. 7 distinct duties, powers or definitions are coded from this article, applying from 2027-12-02.

official text: EUR-Lex (consolidated 27 Jul 2026) · text © European Union (Decision 2011/833/EU) · coding CC BY 4.0 · data: obligations.json · Hugging Face · GitHub

The text

1. Before placing a high-risk AI system on the market, importers shall ensure that the system is in conformity with this Regulation by verifying that:

  1. (a)the relevant conformity assessment procedure referred to in Article 43 has been carried out by the provider of the high-risk AI system;
  2. (b)the provider has drawn up the technical documentation in accordance with Article 11 and Annex IV;
  3. (c)the system bears the required CE marking and is accompanied by the EU declaration of conformity referred to in Article 47 and instructions for use;
  4. (d)the provider has appointed an authorised representative in accordance with Article 22(1).

2. Where an importer has sufficient reason to consider that a high-risk AI system is not in conformity with this Regulation, or is falsified, or accompanied by falsified documentation, it shall not place the system on the market until it has been brought into conformity. Where the high-risk AI system presents a risk within the meaning of Article 79(1), the importer shall inform the provider of the system, the authorised representative and the market surveillance authorities to that effect.

3. Importers shall indicate their name, registered trade name or registered trade mark, and the address at which they can be contacted on the high-risk AI system and on its packaging or its accompanying documentation, where applicable.

4. Importers shall ensure that, while a high-risk AI system is under their responsibility, storage or transport conditions, where applicable, do not jeopardise its compliance with the requirements set out in Section 2.

5. Importers shall keep, for a period of 10 years after the high-risk AI system has been placed on the market or put into service, a copy of the certificate issued by the notified body, where applicable, of the instructions for use, and of the EU declaration of conformity referred to in Article 47.

6. Importers shall provide the relevant competent authorities, upon a reasoned request, with all the necessary information and documentation, including that referred to in paragraph 5, to demonstrate the conformity of a high-risk AI system with the requirements set out in Section 2 in a language which can be easily understood by them. For this purpose, they shall also ensure that the technical documentation can be made available to those authorities.

7. Importers shall cooperate with the relevant competent authorities in any action those authorities take in relation to a high-risk AI system placed on the market by the importers, in particular to reduce and mitigate the risks posed by it.

What it requires, coded

SafeLegalAI's reading of each duty in this article: who, what, from when, under which fine tier, and whether it reaches a firm, chambers, court or legal-AI vendor. Descriptive, not advice; the quoted words are the Regulation's.

  1. Art. 23(1)Conformity assessmentHigh-risk

    Before placing a high-risk AI system on the market, importers must verify conformity assessment, technical documentation, CE marking, EU declaration, instructions and authorised representative appointment.

    "Before placing a high-risk AI system on the market, importers shall ensure that the system is in conformity with this Regulation by verifying that:"
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant to importers bringing non-EU legal-AI systems into the Union market.
    See
    Art. 43 · Art. 11 · Annex IV · Art. 47 · Art. 22(1) · Annex III point 8

  2. Art. 23(2)MonitoringHigh-risk

    Importers with sufficient reason to consider a high-risk AI system non-conforming, falsified or accompanied by falsified documentation must not place it on the market until conformed and must notify if it presents risk.

    "Where an importer has sufficient reason to consider that a high-risk AI system is not in conformity with this Regulation, or is falsified, or accompanied by falsified documentation, it shall not place the system on the market until it has been brought into conformity. Where the high-risk AI system presents a risk within the meaning of Article 79(1), the importer shall inform the provider of the system, the"
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant for distributors or resellers importing high-risk legal-AI tools.
    See
    Art. 79(1) · Annex III point 8

  3. Art. 23(3)TransparencyHigh-risk

    Importers must indicate their name, trade name or trademark and contact address on the high-risk AI system, packaging or accompanying documentation where applicable.

    "Importers shall indicate their name, registered trade name or registered trade mark, and the address at which they can be contacted on the high-risk AI system and on its packaging or its accompanying documentation, where applicable."
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Institutional — Supports traceability for legal deployers and authorities.
    See
    Annex III point 8

  4. Art. 23(4)RequirementHigh-risk

    Importers must ensure storage or transport conditions under their responsibility do not jeopardise compliance with Section 2 requirements.

    "Importers shall ensure that, while a high-risk AI system is under their responsibility, storage or transport conditions, where applicable, do not jeopardise its compliance with the requirements set out in Section 2."
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Institutional — Mostly supply-chain oriented and indirect for legal practice.
    See
    Chapter III Section 2 · Annex III point 8

  5. Art. 23(5)DocumentationHigh-risk

    Importers must keep any notified-body certificate, instructions for use and EU declaration of conformity for 10 years after market placement or putting into service.

    "Importers shall keep, for a period of 10 years after the high-risk AI system has been placed on the market or put into service, a copy of the certificate issued by the notified body, where applicable, of the instructions for use, and of the EU declaration of conformity referred to in Article 47."
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant to importers of high-risk legal-AI systems needing compliance records.
    See
    Art. 47 · Annex III point 8

  6. Art. 23(6)Cooperation with authoritiesHigh-risk

    Importers must provide competent authorities, upon reasoned request, necessary information and documentation to demonstrate conformity and ensure technical documentation can be made available.

    "Importers shall provide the relevant competent authorities, upon a reasoned request, with all the necessary information and documentation, including that referred to in paragraph 5, to demonstrate the conformity of a high-risk AI system with the requirements set out in Section 2 in a language which can be easily understood by them. For this purpose, they shall also ensure that the technical documentation can be"
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant if authorities review imported legal-AI systems.
    See
    Chapter III Section 2 · Annex III point 8

  7. Art. 23(7)Cooperation with authoritiesHigh-risk

    Importers must cooperate with relevant competent authorities in actions concerning high-risk AI systems they placed on the market, especially risk reduction and mitigation.

    "Importers shall cooperate with the relevant competent authorities in any action those authorities take in relation to a high-risk AI system placed on the market by the importers, in particular to reduce and mitigate the risks posed by it."
    Who
    Importer
    From
    (Regulation (EU) 2026/1744 (Digital Omnibus on AI), Art. 1(40), amending Art. 113(c)(i): Art. 6(2)/Annex III high-risk)As enacted in 2024: (Art. 113 second subparagraph); deferred by Regulation (EU) 2026/1744 (Digital Omnibus on AI).Art. 111(2): high-risk AI systems placed on the market or put into service before 2026-08-02 are covered only if they are subject to significant design changes from that date; providers and deployers of high-risk AI systems intended for public authorities must take necessary steps to comply by 2030-08-02. Art. 113(c) separately applies Article 6(1) and corresponding obligations from 2027-08-02. Date deferred by Regulation (EU) 2026/1744 (in force 27 July 2026); as enacted: 2026-08-02 (Art. 113 second subparagraph).
    Fine tier
    Art. 99(4)
    Legal practice
    Reaches legal-AI vendors or public bodies — Relevant for importers of legal-AI systems subject to corrective or risk mitigation action.
    See
    Annex III point 8

Cite

Regulation (EU) 2024/1689, Article 23 (Obligations of importers), as amended by Regulation (EU) 2026/1744, consolidated text of 27 July 2026, https://eur-lex.europa.eu/eli/reg/2024/1689/2026-07-27/eng#art_23 — text © European Union; only the Official Journal is authentic. Coding: SafeLegalAI (published by Cognesio LLP), "EU AI Act, structured", safelegalai.com/regulation/eu-ai-act/article-23, accessed 2026-09-08, CC BY 4.0.