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Card 5 of 15 Provider, deployer, and the flip between them ●●● Sharp edge

How a deployer becomes a provider

A deployer takes on the provider's obligations if it puts its own name or trademark on a high-risk system, makes a substantial modification to it, or changes its intended purpose such that a system becomes high risk.

Why it is like this

Otherwise, a reseller could strip a system of its accountability simply by relabelling it, and a deployer could repurpose a low-risk system into a consequential one with nobody answering for the result.

Not to be confused with

A question of how much code you wrote. Fine-tuning, re-branding or pointing a general tool at an Annex III use can each flip the role — without touching the model's architecture.

In practice

Taking a general-purpose assistant and deploying it, under your own brand, to screen job applications flips you to provider of a high-risk system.

Source: Regulation (EU) 2024/1689 (AI Act) — Article 25. Read on .

Odd one out Check yourself

Three of these turn a deployer into a provider. Which one does not?

  1. Putting its own trademark on the high-risk system
  2. Making a substantial modification to the system
  3. Changing the intended purpose so the system becomes high risk
  4. Deploying the system in a second EU member state
Show the answer

Deploying the system in a second EU member state

Geography is irrelevant — the regulation is EU-wide. The other three are the three triggers in Article 25(1), word for word.