Welcome to Privacy Minders: The EU Authorized Representative for third country Providers of General-Purpose Artificial Intelligence (AI) Models under Article 54 of the AI Act looking to enter the European Market
What is a General-Purpose AI Model?
An AI model trained on a large amount of data using self-supervision at scale, displaying significant generality and capable of performing a wide range of distinct tasks and being integrated into various downstream systems or applications, excluding models used for research, development, or prototyping before market placement.
Which organizations require an Authorized Representative for General-Purpose AI Models?
Providers established in third countries (non EU) must appoint an authorized representative in the Union before placing a general-purpose AI model on the Union market.
A ‘provider’ refers to:
- A natural or legal person
- A public authority
- An agency
- Another body
Who:
- Develops a general-purpose AI model.
- Has a general-purpose AI model developed.
- Places the AI model on the market
- Puts the AI system into service under its own name or trademark, whether for payment or free of charge.
Examples of organisations that may provide General- Purpose AI Models and are obliged to appoint an EU Authorised Representative Providers of:
- Large Language Models
- Image Recognition Systems
- Speech-to-Text Models
- Recommendation Engines
- Predictive Analytics Models
- Autonomous Vehicle Systems
- Chatbots
- Anomaly Detection Systems
- Natural Language Understanding Models
Before entering the European Market
The provider of a General-Purpose AI model is obliged to appoint an EU AI Authorised Representative before entering into the European Market.
Which third country organisations are exempt from the obligation to appoint an EU Authorised Representative?
If General-Purpose AI models are released under a free and open-source license. This license must allow access, use, modification, and distribution of the model, and the model’s details—such as its parameters, weights, architecture, and usage information—must be made publicly available. However, this exemption does not apply if the general-purpose AI models pose systemic risks.
Authorised Representative Role
The Authorised Representative, natural or legal person, located or established in the EU is appointed under written mandate by the Provider:
1. Performs Mandated Tasks:
- Executes tasks as specified in the written mandate received from the provider.
- Provides a copy of the mandate to the AI Office upon request, in one of the official languages of the Union institutions.
2. Verifies Documentation and Compliance:
- Verifies that the technical documentation specified in AI Act’s Annex XI has been prepared.
- Verifies that all obligations outlined in Article 53 and, if applicable, Article 55 (obligations for General Purpose AI models with systemic risks) have been fulfilled by the provider.
3. Maintains Documentation:
- Preserves a copy of the technical documentation specified in Annex XI available for the AI Office and national competent authorities for 10 years after the general-purpose AI model is placed on the market.
- Maintains the contact details of the provider that appointed the authorized representative.
4. Provides Information Upon Request:
- Supplies the AI Office with all necessary information and documentation, to demonstrate compliance.
5. Cooperates with Authorities:
- Collaborates with the AI Office and competent authorities upon a reasoned request, particularly in relation to actions concerning the general-purpose AI models or their integration into AI systems within the Union.
6. Contact Point for Compliance Issues:
- Address the AI Office or competent authorities on all issues related to compliance with the Regulation, in addition to or instead of the provider.
Representative Services
- Appointment of a head of communication from Privacy Minders.
- Provision of a dedicated email address for internal communication between the Provider and Privacy Minders and external communication with AI Office and national competent authorities.
- Issuance of a certificate to the provider confirming Privacy Minders' appointment as the EU Authorized Representative for General-Purpose AI Models.
- Technical Documentation Retention as required by Annex XI of Ai Act.
- Verification that the technical documentation specified in Annex XI has been drawn up and that obligations in article 53 and 55 (where the model poses systemic risks) have been fulfilled.
- Contact Information Disclosure and Maintenance (name, physical address, email) at one EU contact location, available for the AI Office and national competent authorities.
- Availability to be addressed, in addition or instead of the provider by the AI office or the competent authorities, on all issues related to ensuring compliance with the AI Act.
Get in Touch with Privacy Minders: Your EU Authorized Representative for General-Purpose AI Models
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