A European University Network Just Asked Whether Your AI Grading Tool Has an EU Authorised Representative: Answering the Article 30 Questions

A European university network just asked whether your AI grading tool has an EU authorised representative: answering the Article 30 questions

Your account executive flagged the question during the annual renewal call. A pan-European university consortium running your AI essay grading and assessment tool across campuses in Germany, France, and the Netherlands has added a new requirement to their vendor review checklist. Before signing the renewal, their central procurement office is asking:

"Article 30 of the EU AI Act requires providers of high-risk AI systems established outside the EU to appoint an authorised representative in the EU. Is your company established in the EU? If not, have you appointed an EU authorised representative, and if so, who are they and how can they be contacted?"

This question is appearing in procurement cycles for non-EU AI vendors, and for EU vendors whose contracting entity is outside the EU. Here is what Article 30 requires and how to answer it.

What Article 30 Actually Requires

Article 30 establishes an obligation for providers of high-risk AI systems who are not established in the EU. Before making their system available on the EU market, these providers must appoint — in writing — a natural or legal person established in the EU as their authorised representative.

The authorised representative has a defined role under the regulation. They must be mandated in writing by the provider to perform specific tasks on their behalf: registering the system in the EU AI Act database, verifying that the required technical documentation and conformity assessment have been completed, keeping a copy of the EU Declaration of Conformity and the technical documentation, and cooperating with national competent authorities on request.

The authorised representative is not simply a contact point — they have regulatory accountability. They can be held liable by national authorities for failures of the provider to comply with their obligations in specific circumstances.

Article 30(2) sets out what the mandate must cover: it must allow the authorised representative to fulfil their tasks, and the provider must supply them with all necessary information and documents. The authorised representative must also be able to cooperate with competent authorities and act on behalf of the provider.

Who Needs an Authorised Representative

If your company is established in the EU — meaning you have a registered entity, subsidiary, or branch in an EU member state that is the legal entity placing the system on the EU market — you do not need an authorised representative under Article 30. You are the provider for EU purposes.

If your company is established outside the EU (including the UK post-Brexit), and you are making your AI grading system available to EU educational institutions, you must have an authorised representative before you can lawfully do so.

Two situations create ambiguity. First: if your US or UK parent company sells through an EU subsidiary, the subsidiary is the provider for EU purposes if it is the entity that places the system on the market. Second: if you sell direct to EU customers without an EU entity, you need an authorised representative regardless of where your customers' contracts are signed.

What You Need to Document

Your establishment status. State clearly whether your company has an EU-established legal entity. If so, name the entity, its registered jurisdiction, and confirm it is the provider placing the system on the EU market.

Your authorised representative, if applicable. If you are not EU-established, name the authorised representative: their full legal name, registered address in the EU member state, and contact details. Provide the reference number of your written mandate with them.

The representative's scope. Confirm that your authorised representative has been granted the mandate required under Article 30 and has access to your technical documentation and EU Declaration of Conformity.

Registration status. Article 30(4) requires the authorised representative to register the high-risk system in the EU AI Act database under Article 71. Confirm whether this registration has been completed, or provide your expected timeline.

Why This Question Blocks Procurement in Education

University procurement teams in the EU have heightened sensitivity to regulatory status because public institutions face scrutiny from national data protection authorities and education ministries. A vendor that cannot confirm their Article 30 status is a vendor that cannot be approved by the legal review committee — regardless of how good the product is.

The answer your procurement team needs is short and unambiguous: either you are EU-established and name the entity, or you name your authorised representative and provide their contact details. Anything less than that will be sent back.

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