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Provider and Deployer (AI Act)

Fornitore e Deployer (AI Act)

Provider and deployer are the two fundamental roles the EU AI Act distinguishes along an AI system's value chain, each with different regulatory obligations. The provider is whoever develops an AI system, or has it developed on their behalf, and places it on the market or puts it into service under their own name or trademark. The deployer, by contrast, is whoever uses an AI system already developed by others, in the course of their professional activity.

Definition

How it works

The distinction is crucial because regulatory obligations differ and are proportionate to the role: the provider is mainly responsible for the system's intrinsic compliance (risk management, data quality, technical documentation, conformity assessment), while the deployer is mainly responsible for the correct use of the system in its specific context, including human oversight and use consistent with the instructions provided. In some cases an organization may take on both roles simultaneously, for example when it substantially modifies a system purchased from a third party.

Applications

For companies, understanding which role they occupy relative to each AI system used is the first step to correctly identifying which obligations apply: a company integrating a third party's model into its own product might discover it is considered a provider, with obligations far broader than those set for a simple deployer.

History & etymology

This distinction between roles along the value chain mirrors a model already used in European product safety law, which has long distinguished manufacturers, importers, distributors and end users, each with responsibilities proportionate to their role in the supply chain.

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