Article 91 of Regulation (EU) 2024/1689 — Power to request documentation and information. Official text, practical interpretation, key obligations and compliance implications.
Article 91 is the first rung of the Commission's GPAI enforcement ladder: the power to demand the paperwork. The technical documentation of Articles 53 and 55 exists to be producible — this is the provision that calls the bluff.
Official Text Summary
The Commission may request a provider of a general-purpose AI model to supply the documentation drawn up in accordance with Articles 53 and 55, or any additional information necessary to assess the provider's compliance with the Regulation. The Board may also submit a reasoned request asking the Commission to trigger such a request where that is necessary for its tasks. Requests state the legal basis and purpose, specify what information is required and set a time limit; the provider, or its authorised representative, supplies the information. Supplying incorrect, incomplete or misleading information — or none — is independently finable under Article 101, separate from any underlying breach.
Key Obligations
- The Commission may request a GPAI provider to supply the documentation drawn up under Articles 53 and 55, or any additional information needed to assess compliance with the Regulation
- The Board may also, upon reasoned request, ask the Commission to trigger such a request
- Requests state a time limit; the provider — or its authorised representative — must supply the information, and inaccurate or incomplete answers are independently finable
Compliance Timeline
Applies from 2 August 2026; the 2026 Digital Omnibus deferred the substantive high-risk obligations (Annex III to 2 December 2027, Annex I to 2 August 2028) but did not move this provision.
Official AI Act Compliance Deadline Calendar
Updated · Sources: Regulation (EU) 2024/1689 and the 2026 Digital Omnibus on AI.
| Obligation | Applies to | Original date | New date | Status | Countdown | Legal basis |
|---|---|---|---|---|---|---|
| Prohibited Practices (Art. 5) | All providers and deployers | active | — | AI Act Art. 5 | ||
| GPAI Rules (Chapter 5) | GPAI model providers | active | — | AI Act Art. 51-56 | ||
| Commission Enforcement Powers over GPAI | GPAI model providers | active | — | AI Act Art. 88-94, 101 | ||
| Transparency Obligations (Art. 50) | Providers and deployers of chatbots, generative, emotion recognition systems | active | — | AI Act Art. 50 | ||
| New Art. 5 Prohibition (CSAM / non-consensual intimate imagery) | Providers and deployers of generative AI systems | active | — | AI Omnibus 2026 Art. 5 | ||
| AI-Generated Content Marking (pre-existing systems) | Providers of generative AI systems on the market before 2 Aug 2026 | active | — | AI Act Art. 50(2) — transitional | ||
| Regulatory Sandboxes | National competent authorities | deferred | — | AI Omnibus 2026 Art. 57 | ||
| High-risk AI — Annex III (standalone) | Providers of standalone Annex III systems | deferred | — | AI Omnibus 2026 Art. 6(2) | ||
| High-risk AI — Annex I (embedded) | AI embedded in Annex I regulated products | deferred | — | AI Omnibus 2026 Art. 6(1) |
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AI Act meets DORA and NIS2
Is your organisation subject to both the AI Act and DORA? The two regulations intersect on the operational resilience of financial AI systems. Our sister site regulation-dora.eu covers DORA in depth — including what the AI Act adds on top of an existing DORA programme.
The AI Act for financial institutions ↗ Explore regulation-dora.eu ↗Frequently Asked Questions
Anything within the Article 53 and 55 perimeter — model and training documentation, downstream information packages, copyright policy, systemic-risk assessments, incident logs — plus any additional information genuinely necessary to assess compliance. Fishing beyond that purpose is what Article 94's procedural rights are for.
Treat the Article 53/55 documentation as a living, producible artefact — versioned, current and reviewable at the deadline a request sets, typically short. A provider that scrambles to write documentation after the request arrives has already converted a paperwork exercise into an enforcement problem.
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