EU AI Act Art.23: Obligations of importers

Article 23 of the EU AI Act binds the importer. It requires Importers of high-risk AI systems shall verify that the conformity assessment has been carried out, that the technical documentation is. This page states what it requires, who it binds and the evidence to keep. Browsing is free; the conformance kit is USD 499.

Specifics

Who does Art.23 bind?

The article binds the importer. The Act places each duty on a named party in the value chain, so a system can carry a provider duty and a deployer duty at once. Confirm your own position against the text; this page names the party, it does not rule on your facts.

Applies with the high-risk regime: 2 December 2027 for stand-alone systems listed in Annex III, and 2 August 2028 for AI embedded in regulated products listed in Annex I (Article 113, as amended by Regulation (EU) 2026/1744). See the full timeline.

What does Art.23 require?

Importers of high-risk AI systems shall verify that the conformity assessment has been carried out, that the technical documentation is in place, that the CE marking and EU declaration of conformity are present, that an authorised representative has been appointed where required, and shall keep records and cooperate with authorities; importers shall not place a non-compliant system on the market.

This is our plain-language statement of the article, not the text of the regulation. Read the article: Art.23 (Regulation (EU) 2024/1689 on EUR-Lex).

What evidence should we keep for Art.23?

What does a linked control mean here?

A linked control is a NIST AI RMF or ISO/IEC 42001 control that the held rule set records as a topical match, with a confidence and a one-line reason. It does not establish that meeting one requirement satisfies the other, it is not legal advice, and it is not certification. Where no control is recorded, the page says so and does not guess. Sources: the NIST AI RMF and ISO/IEC 42001.

Which NIST AI RMF controls line up with Art.23?

No NIST AI RMF control is recorded as a match for this obligation in the held rule set. It is left unlinked and marked, never guessed.

Which ISO/IEC 42001 controls line up with Art.23?

1 control in the held rule set is recorded as a topical match for this obligation, each with its confidence and reason.

What does the conformance kit add for Art.23?

The kit renders this obligation into your own role checklist with the evidence register, the linked controls and a CSV export, for USD 499 one off. See what is in the kit or open it.