Am I a provider or a deployer?

The two main roles

• Provider (Art. 3(3)) — you develop, train, or substantially modify an AI system and place it on the market or put it into service under your own name or trademark. Providers carry the heaviest obligation set: risk management, technical documentation, conformity assessment, registration.
• Deployer (Art. 3(4)) — you use an AI system under your authority, but a third party built it. Think: an HR team using a vendor's CV-screening tool. Deployer duties centre on using the system as instructed, human oversight, and monitoring.

A simple test: if the system breaks its promises, whose name is on it? That party is usually the provider.

The Art. 25 "own-name upgrade"

Roles are not fixed labels — they follow behaviour. Under Art. 25, a deployer (or distributor) is treated as the provider of a high-risk system if it:

• puts the system on the market under its own name or brand,
• substantially modifies it, or
• changes its intended purpose so it becomes high-risk.

Rebranding a vendor's chatbot as "YourCo Assistant" or retraining it for a new high-risk purpose means you inherit the full provider obligation set for that system.

Importer and distributor, briefly

• Importer (Art. 23) — places a system from outside the EU on the EU market. Must verify conformity, CE marking and documentation before doing so.
• Distributor (Art. 24) — makes a system available on the EU market without modifying it. Verifies markings and paperwork, and holds non-conforming systems back.

How Veritome resolves your role

Step 1 of the registration wizard asks for your base role, then runs the Art. 25 check for deployers and distributors: "Do you put this system on the market under your own name or brand, substantially modify it, or change its intended purpose?" Answer yes and Veritome upgrades you to Provider for that system, so the obligation engine generates the provider set — the review step shows whether the upgrade was applied.