Provider or deployer? Working out your role
Your duties depend on your role. Most companies are deployers, but some actions turn you into a provider.
Provider
You're the provider if you develop an AI system, or have it developed for you, and put it on the market or into service under your own name or brand. Providers carry most of the obligations for high-risk systems.
Deployer
You're a deployer if you use an AI system under your authority in your professional activity. A bank using a vendor's credit-scoring model is a deployer.
Importer and distributor
An importer is an EU business that places on the EU market an AI system carrying the name of a company outside the EU. A distributor makes an AI system available further along the chain without changing it. Both must check that the provider has done its part.
When a deployer becomes a provider
Under Article 25, you take on the provider's obligations if you:
- put your own name or trademark on a high-risk system already on the market;
- make a substantial modification to a high-risk system; or
- change the intended purpose of an AI system (including a general-purpose one) so that it becomes high-risk.
You license a general chatbot and configure it to pre-screen job applicants. You have changed its purpose to a high-risk use, so you become the provider of that high-risk system.
Why this matters in V77 Trust
When you add a system, you record your role in the value chain. V77 Trust uses it to pick the controls that apply. A deployer of a high-risk system gets deployer controls; a provider gets the full set.
This page explains the law to help you find your way. It isn't legal advice.