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Last verified October 31, 2026, against the AI Act as amended by the Digital Omnibus on AI (Regulation (EU) 2026/1744).

Where it comes from. Art. 3(3) of the EU AI Act: “a natural or legal person, public authority, agency or other body that develops an AI system or a general-purpose AI model or that has an AI system or a general-purpose AI model developed and places it on the market or puts the AI system into service under its own name or trademark, whether for payment or free of charge”.

Example

A software company in Denver adds a feature that drafts replies to customer emails and sells its product to firms in France. It places that AI system on the EU market under its own name, so it is the provider, even though the feature runs on another company’s model. The Act calls this a “downstream provider” (Art. 3(68)). The model’s vendor is the provider of the model, with its own duties.

What it means for you

  • Roles are set per system. The same company can be the provider of what it sells and the deployer of the tools it buys.
  • Every provider in scope takes AI literacy measures (Art. 4) and must stay clear of the banned practices (Art. 5).
  • Providers of systems that interact directly with people, and of generative systems, have transparency duties since August 2, 2026 (Art. 50(1)-(2)).
  • Providers of high-risk AI systems carry most duties (Art. 16) from December 2, 2027 (Annex III) or August 2, 2028 (Annex I). A provider based outside the EU also appoints an authorized representative (Art. 22).
  • From those dates, you can become the provider of someone else’s high-risk system by putting your name on it, substantially modifying it, or giving it a high-risk purpose (Art. 25(1)).
  • A provider of a general-purpose AI model has the model duties in Art. 53.

This page is general information, not legal advice.

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