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Chapter III, Section 3 — Obligations of providers and deployers of high-risk AI systems and other partiesArticle 24

Article 24: Obligations of Distributors

Applies from 2 Aug 20264 min readEUR-Lex verified Apr 2026

Article 24 places verification obligations on distributors of high-risk AI systems. Before making a system available on the market, distributors must verify that: the system bears the CE marking; it is accompanied by the EU declaration of conformity and instructions for use; and the provider and importer have complied with their respective obligations. Distributors must also ensure storage and transport conditions do not compromise compliance, and inform the provider or importer and market surveillance authority if the system presents a risk.

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Who does this apply to?

  • -Distributors making high-risk AI systems available on the EU market
  • -Resellers, marketplace operators, and channel partners in the AI supply chain
  • -Market surveillance authorities verifying distributor compliance

Scenarios

A European IT distributor resells a high-risk AI-powered medical diagnostic tool. Before shipping to hospitals, it verifies CE marking, EU declaration, and instructions for use.

Compliant with Article 24 verification duties.
Ref. Art. 24

A distributor receives complaints from deployers about anomalous AI behaviour but does not inform the provider.

Non-compliant — Article 24 requires the distributor to inform the provider/importer and, where relevant, market surveillance authorities.
Ref. Art. 24

Distributor verification duties

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

1. The system bears the CE marking (Article 48) 2. It is accompanied by the EU declaration of conformity (Article 47) and instructions for use 3. The provider has complied with Article 16 obligations 4. The importer has complied with Article 23 obligations (where applicable)

Distributors must also ensure that storage and transport conditions under their responsibility do not jeopardise compliance with Chapter III, Section 2 requirements.

Risk notification and cooperation

If a distributor considers or has reason to consider that the system is not in conformity or presents a risk:

  • Do not make the system available until brought into conformity
  • Inform the provider or importer
  • Inform the market surveillance authority of the Member State(s) where the system is available
  • Cooperate with competent authorities on corrective actions including withdrawal or recall

How Article 24 connects to the rest of the Act

Compliance checklist

  • Before making available: verify CE marking, EU declaration, instructions for use.
  • Verify provider (Article 16) and importer (Article 23) compliance.
  • Ensure storage and transport do not compromise system compliance.
  • If non-conformity or risk suspected: halt availability and notify provider/importer and market surveillance authority.
  • Cooperate with authorities on corrective actions.
  • Monitor for re-qualification triggers under Article 25.
Read the official text on EUR-Lex

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Frequently asked questions

Is a SaaS reseller a distributor?

If the reseller makes the AI system available on the Union market in the course of commercial activity (without being the provider or importer), it likely qualifies as a distributor under Article 3(7). Confirm with the authentic text.

What if the distributor modifies the system?

Modifications that change the intended purpose or constitute substantial modifications may re-qualify the distributor as a provider under Article 25, triggering full provider obligations.

Can a distributor be held liable as a provider under the AI Act?

Yes. Under Article 24(2), if a distributor places a high-risk AI system on the market under their own name or trademark, or substantially modifies it, they become a provider under Article 25 and must fulfil all provider obligations.