What is a “provider” under the EU AI Act?
A provider is any natural or legal person that develops an AI system or a general-purpose AI model — or has one developed — and places it on the EU market or puts it into service under its own name or trademark, whether for payment or free of charge. Providers carry the Act’s heaviest obligations: conformity assessment, technical documentation, risk management, logging, registration and CE marking for high-risk systems; Article 53 duties for GPAI models.
How you can become a provider without noticing
- White-labelling: putting your name or trademark on a third-party high-risk system;
- Substantial modification: changing a system’s intended purpose or materially altering it — including repurposing a general system into a high-risk use;
- Fine-tuning a GPAI model: provider status for the modification, with training-content summary duties.
Provider vs deployer in one line
The provider builds and ships; the deployer uses under its own authority. Contracts should say explicitly who wears which hat for every integration — the allocation drives documentation, liability and who answers regulators. Non-EU providers serving the EU market must also appoint an EU authorised representative.