Which role do youhold under theEU AI Act?
Whether you are a provider or a deployer decides who builds in the AI notice and who keeps the logs.
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Discuss AI governance or call: +49 151 1576 5566Providers, deployers, importers and distributors are the roles the EU AI Act attaches its obligations to. Which one fits decides practical things, such as who builds in the AI notice and who keeps the logs.
- Provider: builds an AI system or has it built and releases it under its own name (Art. 3(3)).
- Deployer: uses it professionally under its own authority (Art. 3(4)).
- Importers, distributors and authorised representatives carry their own duties.
What is the difference between a provider and a deployer under the AI Act?
If you buy a ready-made chatbot and put it on your website, you are almost always the deployer. Things can look different if you have an assistant built specifically for you and offer it under your own name, because then your business may move into the provider role itself. Where exactly the line runs cannot be said across the board (the contract and the way the system is set up usually tip the balance), and we would rather take one more look before the system goes live.
Which duties come with being a provider or a deployer?
For transparency under Article 50 the work is split fairly clearly. The provider builds the system so that people in a conversation learn they are dealing with AI, and it marks generated content in a machine-readable way. Disclosing deepfakes, on the other hand, is the deployer's job.
High-risk systems follow the same pattern. The provider makes sure logging is possible at all and explains how in the instructions for use. The deployer sticks to those instructions, keeps an eye on operation and keeps the logs that end up on its side.
What applies to importers and distributors under the AI Act?
Besides providers and deployers, the regulation names importers, distributors and authorised representatives. All of them appear in Article 99(4), which sets fines of up to 15 million euros or 3 percent of worldwide annual turnover for breaches of their obligations under specific articles. Anyone looking up AI importer obligations 2026 or AI distributor obligations 2026 will meet this tier as the common reference point. For AI literacy, though, importers and distributors play no part, because Article 4 is addressed to providers and deployers only.
Frequently asked questions
Who has to build the AI notice into a chatbot?
Article 50(1) obliges the provider to design the system accordingly. But your customer sees your chat window and your name, so a missing notice reflects on you, so check yourself whether it is there.
Who keeps the logs, the provider or the deployer?
Both, each to the extent the logs are under their control, under Article 19 and Article 26(6) respectively.
Terms you should know in the same context
EU AI Act · AI disclosure obligation (Article 50) · Logging obligation (AI Act) · AI literacy (Article 4) · AI governance · Back to the AI glossary A to Z
Once you have written down your role for each AI system, every new duty tells you straight away whether it concerns you.