What does Article 24 of the EU AI Act require distributors to do?

Before making a high-risk AI system available on the EU market, distributors must verify the CE marking, the presence of a copy of the EU declaration of conformity and instructions for use, and compliance by the provider and importer with their identification obligations, and must withhold, correct, withdraw or escalate non-conforming systems and cooperate with authorities.

Who is a distributor under the EU AI Act?

Any natural or legal person in the supply chain, other than the provider or the importer, that makes an AI system available on the Union market, as defined in Article 3(7). This typically covers resellers, channel partners and similar intermediaries.

What must a distributor do if it suspects non-conformity?

If the system has not yet been made available, the distributor must not make it available until it is brought into conformity. For systems already on the market, the distributor must take or ensure corrective actions, withdrawal or recall, and for systems presenting a risk under Article 79(1), immediately inform the provider or importer and the competent authorities.

Do distributors have to check the technical documentation?

No. The Article 24 verification covers the CE marking, the accompanying copy of the EU declaration of conformity, the instructions for use and the upstream identification obligations. The deeper documentation checks sit with importers under Article 23 and with the conformity assessment itself.

When does a distributor become a provider?

Under Article 25, when it puts its name or trademark on a high-risk AI system already on the market, makes a substantial modification to such a system, or modifies the intended purpose of an AI system so that it becomes high-risk. It then assumes the full provider obligations.

Quick answer

Article 24 of the EU AI Act requires distributors, before making a high-risk AI system available on the EU market, to verify that it bears the CE marking, is accompanied by a copy of the EU declaration of conformity and instructions for use, and that the provider and importer have complied with their key obligations. Distributors must act on non-conformity and cooperate with authorities.

Updated June 2026 · MmowW AI Compliance

EU AI Act Article 24: Obligations of Distributors of High-Risk AI Systems

What Article 24 Covers

Article 24 of Regulation (EU) 2024/1689 addresses distributors, defined in Article 3(7) as natural or legal persons in the supply chain, other than the provider or the importer, that make an AI system available on the Union market. In software markets this captures resellers, value-added channel partners, marketplaces acting as distributors and system integrators who pass on a high-risk AI system without becoming providers themselves. The regulation enlists them as a final checkpoint before a system reaches deployers.

The Pre-Market Verification Duties

Before making a high-risk AI system available on the market, distributors shall verify that:

The system bears the required CE marking under Article 48.
It is accompanied by a copy of the EU declaration of conformity referred to in Article 47 and by instructions for use.
The provider and, where applicable, the importer have complied with their respective obligations, specifically the provider obligations laid down in Article 16 points concerning the indication of name and contact details and the importer obligations in Article 23(3) concerning importer identification.

The distributor's check is lighter than the importer's: it focuses on markings, accompanying documents and the visible identification duties of the upstream actors, rather than on the conformity assessment file itself. It is nonetheless a real legal duty with independent liability attached.

Duties When Something Is Wrong

Article 24 contains a graduated response scheme:

Where a distributor considers or has reason to consider, on the basis of the information in its possession, that a high-risk AI system is not in conformity with the requirements of Section 2 of Chapter III, it shall not make the system available on the market until the system has been brought into conformity.
Furthermore, where the system presents a risk within the meaning of Article 79(1), the distributor shall inform the provider or the importer of the system, as applicable, to that effect.
Distributors shall ensure that, while a high-risk AI system is under their responsibility, storage or transport conditions, where applicable, do not jeopardise its compliance with the Section 2 requirements.
A distributor that considers or has reason to consider, on the basis of the information in its possession, that a system it has already made available on the market is not in conformity shall take the corrective actions necessary to bring it into conformity, to withdraw it or recall it, or shall ensure that the provider, the importer or any relevant operator, as appropriate, takes those corrective actions. Where the system presents an Article 79(1) risk, the distributor shall immediately inform the provider or importer and the authorities competent for the system concerned, giving details in particular of the non-compliance and of any corrective actions taken.

Cooperation with Authorities

Upon a reasoned request from a relevant competent authority, distributors shall provide that authority with all the information and documentation regarding their actions under the article that is necessary to demonstrate the conformity of the system. Distributors shall also cooperate with authorities in any action those authorities take in relation to a high-risk AI system they have made available, in particular to reduce or mitigate the risk it poses.

How to Implement Article 24 in Practice

Classify the catalogue. A distributor first needs to know which of the AI systems it resells are high-risk under Article 6 and Annex III, because the Article 24 duties attach only to those.
Create an onboarding gate per product: CE marking present, copy of the EU declaration of conformity on file, instructions for use available in the languages of the target markets, provider contact details indicated, importer identification present for third-country products.
Re-run the gate on version changes that the provider flags as substantial modifications, since the declaration and marking attach to an assessed configuration.
Define an incident escalation path: who in the distributor decides to suspend sales, how the provider or importer is notified, and when authorities must be informed for risk cases.
Keep records of the verifications performed, because the cooperation duty means a market surveillance authority can ask the distributor to demonstrate its own diligence, not just forward the provider's documents.
Reflect the duties in reseller agreements: documentation delivery, update notices, the right to suspend distribution on non-conformity, and cost allocation for recalls.

A Concrete Example

A Munich-based IT reseller adds an AI shift-scheduling and worker-evaluation suite to its portfolio. Because the system makes decisions affecting work-related relationships, it falls within Annex III point 4 and is high-risk. Before the first sale, the reseller confirms the CE marking on the product documentation, files the EU declaration of conformity, checks that German-language instructions for use are available and that the provider's and importer's names and addresses appear as required. Months later, a deployer reports that the system behaves erratically after an update. The reseller pauses sales, informs the importer, and when the importer confirms a defect affecting worker evaluations, supports the recall of the affected version and documents each step for possible authority requests.

How Article 24 Connects to Other Provisions

Article 24 completes the value-chain triangle formed with Article 22 on authorised representatives and Article 23 on importers. Its escape hatch and trap is Article 25: a distributor that rebrands a high-risk system, substantially modifies it, or changes its intended purpose so that it becomes high-risk is no longer a distributor but a provider, with the full Article 16 obligations. The objects of the distributor's verification are created by Articles 47 and 48 and the provider identification duties in Article 16. Enforcement runs through Chapter IX market surveillance, and Article 99 fines for operator obligations apply to distributors in their own right.

Actions to Take Before August 2, 2026

Distributors should inventory their AI portfolio against Annex III now and open conversations with providers and importers about documentation readiness, because a distributor's shelves can only be as compliant as its suppliers' files. Building the onboarding gate, the records system and the contract clauses before August 2, 2026 turns Article 24 into a routine intake step rather than a sales-stopping emergency. This article provides general information about Regulation (EU) 2024/1689 and is not advice for any specific distribution arrangement.

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This article is for informational purposes only and does not constitute legal advice. Regulatory requirements change frequently — verify current rules with official sources. Built by Sawai Gyoseishoshi Office, Hiroshima, Japan.