EU AI ACT AUTHORISED REPRESENTATIVE FOR SWISS BUSINESSES
Sell AI into Europe without an EU office
Switzerland is not an EU member state. Swiss AI companies placing high-risk systems on the EU market must appoint a named Authorised Representative inside the Union — before their first EU customer, not after. We are that representative.
Fixed annual fee · Named EU entity · Compliant from day one
EU AI ACT AND SWISS COMPANIES
Switzerland is outside the EU.
Your AI product is not.
Three things Swiss AI companies get wrong about their EU obligations — and why the AR requirement is the one that costs most to ignore.
The EU AI Act follows your product into the Union
Swiss companies are treated identically to US, UK, or Canadian companies under the Act — as non-EU providers subject to the same obligations when their AI systems reach EU users. The EU-Swiss bilateral agreements do not change this. If your product is used in Germany, France, or any other member state, the Act applies to it.
The Authorised Representative requirement is live
Article 22 of the EU AI Act requires non-EU providers of high-risk AI systems to appoint a named, EU-established Authorised Representative before placing the system on the EU market. This is a precondition for market access, not a post-launch administrative step. Swiss companies with existing EU distribution, EU enterprise clients, or EU API integrations are often already in breach without realising it. A letterbox address in Dublin or Amsterdam does not satisfy the requirement.
EU market access is a commercial necessity
Switzerland’s largest export market is the EU. For Swiss AI companies, EU market access is the core commercial question. A missing AR appointment, an unresolved risk classification, or absent technical documentation surfaces in enterprise procurement, investor due diligence, and regulatory inquiry — precisely when it is most expensive to resolve.
Swiss AI companies have unique advantages in the EU market — regulatory credibility, proximity, and established commercial relationships. The EU AI Act AR requirement is a threshold condition for using those advantages. This service puts a named EU entity on your documentation so you can focus on the market, not the compliance gap.
WHAT’S INCLUDED
Everything required for a compliant EU AI Act presence
A substantive legal appointment that satisfies Article 22 — not a form-filling service that leaves you exposed the moment a regulator asks a real question.
Named EU Authorised Representative
A specialised entity established in the EU, appointed under Article 22, identified in your technical documentation and EU AI database registration. Legal standing with EU market surveillance authorities — the person they write to, and the person who can respond substantively on your behalf.
Mandate agreement drafted and executed
A compliant appointment document reflecting the Act’s formal requirements — scope of representation, obligations, and terms — ready to include in your technical file and present to any authority or enterprise procurement team that asks for it.
Technical documentation copy maintained
Your technical documentation and EU declaration of conformity are held as required by Article 22 — available to market surveillance authorities on request, maintained and updated as your product develops.
Authority correspondence handling
All EU regulatory authority correspondence relating to your system is received, escalated, and handled in coordination with your team. You are notified immediately. No position is taken without your involvement. No response goes without your approval.
Annual review and regulatory alerts
An annual call covering product changes, new deployments, and regulatory developments. Alerts when enforcement activity, Commission guidance, or harmonised standard publications affect your system’s category.
Priority AI product assessment
If your AI product changes during the year and raises a reclassification question, you are prioritised. The conversation is included in the service — no additional charge for the call that keeps your compliance position current.
About the provider: (yes, that’s real me)
I’m Yuliia Habriiel — a regulatory lawyer who spent years inside EU digital regulation: not just the AI Act, but GDPR, NIS2, DORA, the Cyber Resilience Act, and ISO 42001.
I build compliance infrastructure for a living, so I know the difference between a requirement that’s theatrical and one that will actually get enforced. The EU AI Act is written at the level of the product — yet almost everyone is still trying to comply at the level of the organisation. That mismatch is where companies get caught.
When you work with me, you’re not getting a generic audit or AI’s best guess. You’re getting the same legal reasoning the regulators apply, turned on the one thing that matters: the AI system you’re shipping.
Who this service is for:
- Swiss AI companies with existing EU distribution, EU enterprise clients, or EU API users who have not yet established a compliant AR appointment — and need to resolve that position before it surfaces in a procurement process or regulatory enquiry.
- Swiss founders preparing for an EU market launch who want the legal groundwork in place before their first EU customer rather than retrofitting compliance after the fact.
- Swiss scale-ups entering Series A or B whose investors — particularly those with EU portfolio exposure — are asking about EU regulatory positioning as part of their due diligence process.
- Swiss AI companies in regulated sectors — healthtech, fintech, legaltech, HR technology — where high-risk classification under Annex III is likely and the AR requirement is a precondition for operating in the EU market at all.
- Swiss companies that have received enterprise procurement questionnaires from EU buyers asking about AI Act compliance, technical documentation, or EU regulatory standing — and need a compliant answer quickly.
- Swiss AI companies already GDPR-compliant who understand the extraterritorial model and need to extend it to the AI Act without building a separate EU compliance infrastructure from scratch.
No prior legal training required.
What our customers say:
Thank you for sending the strategy doc. I did not even expect it to be customised so it provides a good strategy tool to help me think about developing my application.
Meredith Godat, PhD
Founder, CogniQuest (Switzerland)
We’ve been trying to figure out how the EU AI Act affects our drone platform, especially around AI-based navigation. The report helped make sense of what actually applies to us and what we need to pay attention to. It gave us a much better picture of where we stand and what we need to do next before expanding into the EU market.
Denis Isakovs,
CTO, ProDrone
(Latvia)
Before this report, every AI Act discussion ended in confusion. Now I can confidently present classification decisions to our legal team and explain timelines to stakeholders. Worth every euro.
Robert Müller
Head of Product, MedicaTech Solutions (Germany)
Backed by Our Guarantee
The mandate we execute satisfies Article 22 of the EU AI Act to the letter. If at any point during the engagement a market surveillance authority finds the appointment non-compliant due to anything on our side of the mandate, we resolve it at no additional cost. If you decide during the year that you no longer need the service, we refund the unused portion on a pro-rata basis. What you are paying for is a compliant EU presence, maintained for twelve months. That is what we deliver.
Audit-Proof Documentation
Lifetime AI Act Updates Included
If You Don’t Need It, We Tell You
Flexible Time Investment
Appoint your EU Authorised Representative — compliant from day one
✔︎ Free product scoping assessment
✔︎ Mandate agreement drafted and executed
✔︎ Authority correspondence handling for twelve months
✔︎ Technical documentation copy maintained
✔︎ Annual review call and regulatory alerts
✔︎ Priority reclassification assessment if needed
€2,400/year · Billed annually · No hourly billing · No open-ended scope
Frequently Asked Questions
Does the EU AI Act apply to Swiss companies?
Yes. Switzerland is not an EU member state and is not part of the EU AI Act’s regulatory perimeter. Swiss companies are treated as non-EU providers under Article 2 — subject to the same extraterritorial obligations as US, UK, or Canadian companies when their AI systems reach EU users. The EU-Swiss bilateral framework agreements do not extend to the AI Act. If your product is used in any EU member state, the Act applies to it.
What is an EU AI Act Authorised Representative and why does a Swiss company need one?
An Authorised Representative under Article 22 is a lawyer or 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 Swiss companies placing high-risk AI systems on the EU market, the appointment is a legal precondition for market access — not an administrative formality to complete later. Without a compliant AR on record, a Swiss company is in breach of the Act regardless of how well its product meets the technical requirements.
Does my Swiss AI product count as high-risk under the EU AI Act?
High-risk classification is determined by your system’s function and deployment context, not its technical architecture or how you describe it. Annex III covers AI used in hiring, credit decisions, education, biometrics, critical infrastructure, healthcare, law enforcement, and border management.
If your product touches any of these categories and has EU users, high-risk classification is likely in play. Our AR service includes a product review at onboarding to confirm your classification and flag any issues before the mandate is executed.
Is a registered address in the EU sufficient to satisfy the AR requirement?
No. The Act requires a representative with active legal obligations — to maintain your technical documentation, cooperate with market surveillance authorities, and take corrective action where required. A registered address cannot fulfil any of those obligations. An AR that exists only on paper provides no protection when a regulator asks a substantive question and leaves the Swiss company in the same legal position as having no AR at all.
We have EU distribution partners. Can they act as our Authorised Representative?
Possibly, but with significant caveats. A distributor can act as AR only if they explicitly agree to take on the legal obligations in writing, have the capacity to maintain technical documentation, and can respond substantively to regulatory authorities. Most EU distributors are not equipped for this and are unlikely to agree to the liability it carries. A dedicated AR appointment with a lawyer who understands the Act and your product is a cleaner, safer arrangement — and the one that holds up in a procurement questionnaire or regulatory enquiry.
Switzerland has its own data protection law. Does nFADP compliance help with EU AI Act obligations?
nFADP compliance is useful context and demonstrates regulatory maturity, but it does not satisfy EU AI Act obligations. The two regimes are distinct — nFADP governs data protection; the AI Act governs the AI system itself, its risk classification, technical documentation, transparency, and human oversight. A company that is nFADP-compliant has already demonstrated it can navigate extraterritorial regulation. Extending that posture to the AI Act is the next step.
What happens when a EU market surveillance authority contacts our Authorised Representative?
We receive the correspondence, notify you immediately, and coordinate the response with your team. The AR role is to be the accountable EU point of contact — we do not take positions on your product or make commitments to authorities without your explicit involvement. If an enquiry escalates to formal enforcement proceedings, that is a separate legal engagement agreed before we proceed.
Can Swiss companies be fined under the EU AI Act?
Yes. The Act’s enforcement provisions apply to non-EU providers regardless of where they are established. 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 the Authorised Representative — which is one reason the AR appointment carries real legal weight, and why a letterbox service does not adequately protect a Swiss company.
How long does it take to appoint an EU Authorised Representative?
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.
What if our product changes during the year — does the mandate still cover it?
Material changes to your product — new use cases, new deployment contexts, new data processing — may affect your classification and the scope of the mandate. Contact us before deploying significant changes. If the change is within the existing scope, the mandate covers it. If it represents a material expansion, we agree a scope amendment before it takes effect. The annual review call is designed to catch incremental changes; significant changes should not wait for the annual review.
What is included in the €2,400 annual fee?
Mandate drafting and execution, named AR appointment, authority correspondence handling, 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 documentation drafting — is a separate engagement quoted before any work begins.
The annual fee is fixed and does not vary with the volume of correspondence or regulatory enquiries within the service scope.