What is the difference between a provider and a deployer under the EU AI Act?

A provider develops an AI system, or has it developed, and places it on the market or puts it into service under its own name or trademark. A deployer uses an AI system under its own authority. One organization can hold both roles for different systems.

A provider carries the heaviest obligations. Providers must build the system to the requirements for its risk class, prepare technical documentation, run a conformity assessment, and register high-risk systems in the EU database. The provider role attaches to whoever puts the system on the market, including a company that commissions a model from a vendor and sells it under its own brand.

A deployer uses an AI system in a professional capacity. For high-risk systems, deployers must follow the provider's instructions for use, assign human oversight to competent people, monitor operation, keep logs, and inform affected individuals in the cases the Act specifies. Some deployers, such as public bodies, must also carry out a fundamental rights impact assessment.

The role can change. A deployer that substantially modifies a high-risk system, or puts its own name on it, can become a provider for that system. That is why role mapping should be reviewed whenever a system is adapted or rebranded.

Determining the organization's role is one of the first exercises in the Certified EU AI Governance Professional course, because it decides which obligations apply to each system.

Expert Insight

The role can change: a company that substantially modifies or rebrands a third-party high-risk system can become its provider, so review the role each time a system is adapted.

“Your role under the Act sets your obligations, so write it down for every system.”

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What is the difference between a provider and a deployer under the EU AI Act? – Provider vs Deployer Under the EU AI Ac…