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Your role decides which obligations apply. This page explains the provider, deployer, and dual-role definitions and the Article 25 rules that can turn a deployer into a provider.
Legal basis: EU AI Act Article 3 definitions and Article 25 role allocation.
Most EU AI Act obligations attach to a role. Under Article 3, a provider develops or has an AI system developed and places it on the market under its own name; a deployer uses an AI system under its authority. Many companies are both.
You develop an AI system, or have one developed for you, and place it on the market or put it into service under your own name or trademark. Providers carry the primary compliance burden: technical documentation, conformity assessment, and post-market monitoring.
You use an AI system under your authority for professional purposes. Deployers follow the provider's instructions, ensure human oversight, monitor operation, and meet transparency and notification duties.
You develop your own systems and use third-party systems. You then carry provider obligations for what you build and deployer obligations for what you use.
Article 25 shifts provider responsibilities onto a deployer in specific situations. If any of these apply to a high-risk system, you are treated as a provider and inherit the full provider obligations.
Role-shifting applies only to high-risk systems. Under Article 25(2), the original provider must cooperate and hand over the documentation you need.
The guided intake asks a short set of questions, applies the Article 3 and Article 25 rules, and returns your role together with the obligations that follow from it.
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Yes. If you develop or rebrand AI systems and also use third-party AI systems, you hold both roles and must satisfy both sets of obligations.
Not by itself. Simply using a third-party AI system under your authority makes you a deployer. You only become a provider if you rebrand a high-risk system, substantially modify it, or change its intended purpose so it becomes high-risk (Article 25).
The EU AI Act allocates almost every obligation by role. Providers of high-risk systems must run conformity assessments and maintain technical documentation; deployers must ensure human oversight and, in some cases, complete a fundamental rights impact assessment.
A change not foreseen in the initial conformity assessment that affects compliance with the requirements, or that alters the intended purpose of a high-risk AI system.