Service Overview
Are you placing a high-risk AI system on the EU market from outside the Union?
If your organisation provides a high-risk AI system and is established outside the European Union, Article 22 of the EU AI Act requires you to designate, by written mandate, an authorised representative established in the Union before that system is placed on the EU market or put into service. The representative becomes the formal counterparty for national competent authorities, the European AI Office, market surveillance bodies and notified bodies on every aspect of the system's conformity, registration and post-market lifecycle.
High-risk AI systems are defined in Article 6 and listed in Annex III — covering use cases such as biometric identification, critical infrastructure, education and vocational training, employment and worker management, access to essential private and public services, law enforcement, migration and border control, and the administration of justice and democratic processes. AI systems used as safety components in products covered by Union harmonisation legislation may also fall within scope.
Service Detail
What this service covers
Our focus
A real Irish establishment for high-risk AI providers entering Europe
Lionheart provides Article 22 representation through our Dublin-based EU entity. You are appointing a structured compliance function with a named, accountable contact point — not a forwarding address. Our role is to receive, log and escalate authority correspondence, verify and hold the EU declaration of conformity and technical documentation on your behalf, and act as the cooperation interface for any post-market surveillance or corrective action that may be required.
Built around the duties Article 22 actually imposes
The representative's mandate under Article 22(3) is specific and non-delegable. It includes verifying that the EU declaration of conformity and technical documentation have been drawn up and that the provider has carried out the appropriate conformity assessment procedure; keeping that documentation available to competent authorities and notified bodies for ten years after the system has been placed on the market; cooperating with authorities on any action they take in relation to the system; and where applicable, complying with the registration obligations in Article 49. We have built our service to meet each of these duties as a matter of routine, not exception.
Authority to terminate where the provider acts unlawfully
Article 22 imposes a unique safeguard: where the representative has reason to consider that the provider is acting contrary to its obligations under the AI Act, it must terminate the mandate, immediately inform the relevant market surveillance authority and, where applicable, the relevant notified body. We approach this not as a contractual footnote but as a meaningful aspect of the role — and we explain how our internal escalation procedures work before you sign.
Our services include
Formal designation
Acting as your EU Authorised Representative under Article 22 of the AI Act, by written mandate, with clearly documented scope and procedures.
Ireland-based contact details
Lionheart's Dublin address and a dedicated representative email address, available for inclusion in your technical documentation, instructions for use, EU declaration of conformity and any required public disclosures.
Conformity verification
Verifying that the EU declaration of conformity and technical documentation have been drawn up, and that the provider has carried out the appropriate conformity assessment procedure, before the system is placed on the EU market.
10-year documentation safekeeping
Holding a copy of the technical documentation, the EU declaration of conformity, the contact details of the notified body where applicable, and the mandate, available to competent authorities for ten years after the system has been placed on the market or put into service.
Authority liaison
Acting as the formal contact point for national competent authorities, market surveillance authorities and notified bodies — receiving, logging and forwarding all correspondence without delay.
EU database registration
Supporting registration of the high-risk AI system in the EU database under Article 49, where applicable, and maintaining accurate registration data on file.
Post-market cooperation
Cooperating with authorities on any corrective action, recall, withdrawal or risk-mitigation request, and providing requested information in the language designated by the competent authority.
Escalation procedures
Defined escalation paths and service levels for time-sensitive regulatory communications, including serious incident reporting under Article 73 and any market surveillance request.
Coordinated mandates
Single-relationship handling where Article 22 obligations overlap other Lionheart EU representative services — DSA, GDPR, NIS2, TCOR.
Legal basis: Article 22, EU Artificial Intelligence Act (Regulation (EU) 2024/1689). High-risk AI categories are set out in Article 6 and Annex III. Conformity assessment, technical documentation, post-market monitoring and serious incident reporting obligations are governed by Articles 16, 17, 18, 43, 47, 49, 72 and 73.
Exemptions:
Article 22 does not apply to AI used solely for scientific research and development before placing on the market, nor to certain free and open-source AI made available without monetisation — unless the system is high-risk or constitutes a prohibited AI practice under Article 5. Whether your specific deployment falls within or outside scope is a question worth taking advice on; Lionheart can provide a preliminary assessment.
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Not sure if you are in scope?
Use the guided self-check tool to map which representative obligations may apply.