Guides · Article 50 · EU AI Act
Provider, deployer, distributor, importer — a plain-language orientation
The EU AI Act assigns duties by role, and Article 50 in particular splits its transparency duties between providers and deployers. Distributors and importers are two more roles the Act uses. This guide gives a plain-language, deliberately hedged orientation to all four. It is informational only and not legal advice. These are not the Act's formal definitions — the Regulation defines each role precisely elsewhere — and which role you hold for a given system is a fact-specific question for qualified counsel.
Roughly what each role points at
These are working descriptions to orient you, not the Regulation's defined meanings — do not treat them as the formal legal tests:
- Provider — roughly, the party that develops an AI system, or has one developed, and places it on the market or puts it into service under its own name. Article 50(1) and 50(2) duties fall on providers.
- Deployer — roughly, the party that uses an AI system under its own authority. Article 50(3) and 50(4) duties fall on deployers.
- Distributor — roughly, a party in the supply chain, other than the provider or importer, that makes an AI system available on the market.
- Importer — roughly, a party established in the EU that places on the market an AI system bearing the name of a party established outside the EU.
Why the role is assessed per system
A single organisation can wear more than one hat. For a chatbot you built and offer, you may be provider-side; for a third-party deepfake or emotion-recognition tool you merely use, you may be deployer-side. The role — and therefore which Article 50 paragraph attaches — is assessed for each system, which is why mapping systems to roles is a common documentation step. It is also why these hedged descriptions are only a starting point.
Confirm the classification, don't assume it
Because duties follow the role, getting the role right matters, and the boundaries — especially where you modify or rebrand a third-party system — can shift the analysis. The Regulation's actual definitions govern, not the rough descriptions here. Confirm your role for each system with qualified counsel before deciding which obligations apply.
Common questions
Are these the EU AI Act's official definitions of these roles?
No. These are plain-language, hedged orientations. The Regulation defines provider, deployer, distributor, and importer precisely elsewhere, and which role you hold for a given system is fact-specific — confirm with qualified counsel rather than relying on these rough descriptions.
See what may apply to your business
Answer seven quick questions for an automated, informational indication of which Article 50 obligations appear likely to apply — free, and not legal advice.