Are you a provider or a deployer — and when does that flip?

Article 3(3): a provider is a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model, or has one developed, and places it on the market or puts it into service under its own name or trademark — whether for payment or free of charge. A deployer uses an AI system under its own authority. The distinction turns on whose name is on it and who put it into service, not on who wrote the code.

Article 25 lists them. You put your name or trademark on a high-risk AI system already on the market. You make a substantial modification to a high-risk system that keeps it high-risk. Or you modify the intended purpose of a system — including a general-purpose AI system — that was not classified as high-risk, in a way that makes it high-risk. Each of these makes you subject to the provider obligations of Article 16.

Provider duties for high-risk systems include the risk management system, data governance, technical documentation, record keeping, human oversight design and conformity assessment. Deployer duties are real but far narrower. An organisation that white-labels a vendor's system and assumes it stayed a deployer can be carrying the full provider set without having built any of it.

The name-and-trademark and substantial-modification routes in Article 25 are written for high-risk systems, but the transparency duties in Article 50 also allocate by role: 50(1) and 50(2) are provider duties, 50(4) is a deployer duty. Establishing your role once, per system, answers several questions at the same time.

The Commission's guidelines on the Article 50 transparency obligations, published 20 July 2026 and applying from 2 August, are themselves structured by role: which duties fall on providers and which on deployers. That is a useful cross-check on your own classification — if you cannot place yourself in their structure, the role question is not settled yet.

The free Article 50 check maps one system to the transparency duties in about two minutes, quoting the official text per answer. No sign-up, and the full result before any contact details.