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EU AI Act Art. 23: obligations of importers

Before placing a high-risk system on the market, the importer verifies the conformity assessment, the Annex IV documentation, the CE marking, the declaration and instructions and the authorised representative, and keeps copies for 10 years

By Reviewed

From clause to evidenceThe chain from EU AI Act Art. 23 to its evidence record, in 6 steps; the text alternative lists them and the facts under the figure state each in full.ClauseEU AI ActArt. 23Duty holderImporterApplies from2027-12-02DeferredArtefactImportverification…LayersLayer 02Layer 05Evidence recordEvidence recordv1Same topic elsewhere: no crosswalk topic files this clause yetAs of 2026-09-24 · illustrative, not a claim of conformity From clause to evidenceThe chain from EU AI Act Art. 23 to its evidence record, in 6 steps; the text alternative lists them and the facts under the figure state each in full.ClauseEU AI Act · Art. 23Duty holderImporterApplies from2027-12-02 · DeferredArtefactImport verification record against…LayersLayer 02Layer 05Evidence recordEvidence record v1Same topic elsewhere: no crosswalk topicfiles this clause yetAs of 2026-09-24illustrative, not a claim of conformity
From clause to evidence Build the artefact, then file every output it produces as a record that names AIGE-OBL-EUAIA-ART23. Drawn from chapter 08.
Text alternative
  • Clause: EU AI Act, Art. 23.
  • Duty holder: Importer.
  • Applies from: 2027-12-02, Deferred.
  • Artefact: Import verification record against….
  • Layers: Layer 02, Layer 05.
  • Evidence record: Evidence record v1.
  • Record schema: Evidence record.
  • No crosswalk topic files this clause yet.
Id
AIGE-OBL-EUAIA-ART23
Instrument
EU AI Act (post-Omnibus) law
Compared side by side
ISO 42001 vs EU AI Act · NIST AI RMF vs EU AI Act
Clause
Art. 23
Duty holder
Importer
Authority
National MSA
Applies from
Deferred · Annex III
Later dates
  • Applies to Annex I embedded (product safety-component) systems
  • Deadline for legacy high-risk systems intended for use by public authorities (Art. 111(2))
System class
High-risk (Annex III) · High-risk (Annex I)

The artefact that evidences it

Import verification record against each check; 10-year document copies.

Patterns that build it

No pattern in the catalogue names this clause on its "Maps to" line yet; the artefact above is the engineering answer.

Source

Chapter 08, section EU AI Act, post-Omnibus, checked against its sources on the review date above.

Machine-readable

Cite this obligation

García Aibar, J. (2026). EU AI Act Art. 23: obligations of importers (AIGE-OBL-EUAIA-ART23). In AI Governance Engineering: The Thesis & Body of Knowledge (v0.5.0). https://doi.org/10.5281/zenodo.22956197. https://aigovernanceengineer.com/obligations/aige-obl-euaia-art23. CC BY 4.0

BibTeX

@misc{aige2026obligation,
  author       = {Jorge García Aibar},
  title        = {{EU AI Act Art. 23: obligations of importers (AIGE-OBL-EUAIA-ART23)}},
  howpublished = {In AI Governance Engineering: The Thesis \& Body of Knowledge},
  year         = {2026},
  version      = {0.5.0},
  doi          = {10.5281/zenodo.22956197},
  url          = {https://aigovernanceengineer.com/obligations/aige-obl-euaia-art23},
  note         = {Version 0.5.0}
}