AI Act Notification

Legal Framework

Article 30 of the AI Act establishes the formal notification procedure through which Member States inform the European Commission and other Member States of bodies designated to carry out conformity assessment of high-risk AI systems. This procedure is a cornerstone of the AI Act's regulatory architecture, ensuring that notified bodies meet uniform competence and independence standards across the Union.

Under Article 30, each Member State's notifying authority must transmit a notification to the Commission and to the other Member States that includes comprehensive details about the conformity assessment activities the body is authorized to perform, the specific AI Act requirements and conformity assessment modules covered, and relevant accreditation certificates. The Commission then assigns a unique notification number and publishes the list of notified bodies in the public section of its website. Where a notifying authority withdraws or restricts a notification, the same transparency obligations apply — the authority must inform the concerned body and update the Commission and other Member States accordingly.

The rationale is twofold: first, to create a transparent, centralized registry enabling market participants to verify whether a conformity assessment body is properly notified; second, to give other Member States a basis for raising objections where a notified body may not satisfy the Act's requirements, thereby maintaining mutual trust in the assessment regime.

Key Developments

The AI Act entered into force on 1 August 2024, with its provisions applying in phased stages. The notification framework under Article 30 becomes practically operative as Member States designate their notifying authorities and begin the accreditation and notification process for conformity assessment bodies. Member States were required to designate notifying authorities by 2 August 2026.

The European Commission has begun developing implementing acts specifying the technical requirements for notified bodies, including operational and methodological requirements. The AI Office plays a coordinating role, working with national authorities to harmonize notification standards. Early implementation signals indicate that Member States are taking divergent approaches to accreditation timelines, creating potential friction where notified bodies seek to operate across borders.

The interplay between Article 30 and the broader notification architecture — including Articles 28 (requirements for notified bodies), 29 (notifying authorities), and 31 (changes to notifications) — establishes that notification is not a one-time event but an ongoing supervisory relationship. Any material change in a notified body's scope, structure, or ownership triggers re-notification obligations.

Practical Guidance

• Verify notification scope before engagement: Before contracting with a conformity assessment body, confirm that its notification under Article 30 explicitly covers the relevant AI Act requirements and conformity assessment modules applicable to your high-risk AI system. The Commission's published list is the authoritative reference.

• Monitor notification status continuously: Notification status can change — through withdrawal, restriction, or scope modification under Article 31. Establish a process to track the Commission's notified body registry for any changes affecting your assessment partner.

• Prepare for cross-border recognition issues: Where a notified body in one Member State faces objections from another Member State under the notification procedure, conformity certificates may be called into question. Maintain documentation supporting alternative assessment pathways.

• Engage early with notifying authorities: Organizations developing high-risk AI systems that will require third-party conformity assessment should engage with their national notifying authority during the accreditation phase to understand assessment timelines and capacity constraints, as the pool of notified bodies will initially be limited.

• Document accreditation chain: Ensure that any notified body you work with can demonstrate an unbroken accreditation and notification chain, including the accreditation certificate referenced in the Article 30 notification, to withstand regulatory scrutiny of your conformity assessment.