Assess provider responsibilities: Which missing control is most | AIGP
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Assess provider responsibilities: Which missing control is most direct?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Medium

Own-brand distribution can change the retailer’s statutory role, making provider-responsibility assessment the direct missing control.

The question

Under the EU AI Act, assume all relevant duties apply. A retailer licenses a vendor’s demand-planning model, changes no code, and uses it internally. The retailer then markets the system to other retailers under its own brand. All high-risk technical, data, oversight, transparency, and monitoring controls are otherwise satisfied. Which missing control is most direct?

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  1. Repeat internal model validation
    Validation may support assurance, but the identified gap is legal role allocation created by own-brand distribution.
  2. Assess provider responsibilities ✓
    Marketing the system under its own name requires assessing the retailer’s provider responsibilities under the stated role-changing facts.
  3. Apply only deployer instructions
    Deployer instructions remain relevant internally, but they do not address additional responsibilities arising from placing the system under the retailer’s name.
  4. Issue a customer interaction notice
    An interaction notice addresses people communicating with AI, not the retailer’s changed market-facing actor role.
The trap
Check whether the organization markets the system under its own name before assuming it remains only a deployer.

How to remember it

Own-brand distribution can change the retailer’s statutory role, making provider-responsibility assessment the direct missing control.

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