When Ukraine joins the EU — which remains a multi-year process — Ukrainian companies will transition from third-country providers to EU-established providers, at which point the AR requirement falls away and is replaced by direct compliance obligations. Until accession, the third-country provider framework applies in full.

Companies that establish compliant EU market access now will be better positioned for that transition, not worse.

An Authorised Representative under Article 22 is a firm established in an EU member state, appointed by a non-EU provider to act as their legal point of contact for EU regulatory authorities. For Ukrainian companies placing high-risk AI systems on the EU market, the appointment is a legal precondition for compliant market access — not an administrative step to address once the business is large enough.

Without a compliant AR on record, a Ukrainian company is in breach of the Act regardless of how capable its product is or how established its EU client relationships are.

Possibly, but not automatically. An Estonian e-residency does not create EU legal establishment for AI Act purposes — e-residency is a digital identity, not a corporate presence. A properly constituted EU subsidiary with genuine establishment in a member state could potentially act as its own AR, but only if it is the entity placing the system on the market and it meets the Act’s requirements.

If the Ukrainian parent company is the provider of record, a subsidiary arrangement requires careful legal structuring. Our AR service provides a clean, unambiguous solution regardless of your corporate structure.

Ukraine’s AI sector strengths include areas that map closely onto Annex III high-risk categories — defence-adjacent and dual-use technology, document processing and verification systems, healthcare AI, public administration tools, infrastructure monitoring, and recruitment platforms.

If your product operates in any of these areas and has EU users or EU institutional clients, high-risk classification is likely in play. Our AR service includes a product review at onboarding to confirm your classification before the mandate is executed.

No. Article 22 imposes active legal obligations on the AR — to maintain technical documentation, cooperate with market surveillance authorities, and take corrective action where required. A registered address cannot fulfil any of these obligations. An AR that exists only on paper provides no protection when an EU authority makes a substantive enquiry and leaves the Ukrainian company in the same legal exposure as having no AR at all.

We receive the correspondence, notify you immediately (English or Ukrainian), and coordinate the response with your team. We do not take positions on your product or make commitments to authorities without your explicit involvement.

The AR role is to be the accountable EU point of contact. Decisions about your product and compliance position remain yours. If an enquiry escalates to formal enforcement proceedings, that is a separate legal engagement agreed before we proceed.

Yes. The Act’s enforcement provisions apply to non-EU providers regardless of establishment. Fines for prohibited-practice violations reach €35 million or 7% of global annual turnover. Fines for high-risk system violations reach €15 million or 3% of global annual turnover. EU market surveillance authorities can pursue non-EU companies through their Authorised Representative.

The territorial reach of EU enforcement has been established through GDPR. Ukrainian companies that assumed GDPR enforcement wouldn’t reach them discovered otherwise. The AI Act follows the same model.

The service is fully remote — no physical presence in Ukraine is required at any stage. Scoping, onboarding, mandate execution, annual review calls, and all ongoing communication are conducted digitally. We work with Ukrainian companies across multiple time zones and are experienced with the operational realities facing Ukrainian businesses.

The mandate is executed under EU law and maintained by an EU-established company — your location does not affect the legal validity or practical function of the appointment.

From instruction to executed mandate is typically three to five working days. The mandate is executed once we have sufficient knowledge of your product — its function, deployment context, and current documentation position — to fulfil our obligations under Article 22 responsibly.

We do not accept appointments for products we have no visibility of.

Mandate drafting and execution, named AR appointment, authority correspondence handling for twelve months, technical documentation copy maintenance, annual review call, and regulatory alerts relevant to your system’s category. Work outside that scope — a full reclassification assessment, legal representation in enforcement proceedings, or technical documentation drafting — is a separate engagement quoted before any work begins.

The annual fee is fixed and does not vary with correspondence volume or the number of regulatory enquiries within the service scope.