The buyer can rely on deployer-only responsibilities | AIGP
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The buyer can rely on deployer-only responsibilities: Which prior assumption no longer holds?

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

Substantial modification and changed intended purpose can defeat the assumption that the purchaser has deployer-only duties.

The question

A logistics company in the European Union purchases a scheduling system and initially treats itself only as a deployer. It substantially modifies the system and changes its intended purpose, assuming the EU AI Act conditions for provider-role consequences are met. Which prior assumption no longer holds?

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  1. The scheduling system needs no role analysis after purchase.
    Purchase alone does not settle roles, especially after modification and changed intended purpose.
  2. The company becomes an importer solely because it modified the tool.
    Modification may affect provider responsibilities, but the evidence does not establish automatic importer status from modification alone.
  3. The buyer can rely on deployer-only responsibilities. ✓
    A substantial modification or changed intended purpose can trigger provider-role consequences under the assumed EU AI Act conditions.
  4. The vendor remains responsible for every resulting duty.
    Commercial procurement does not preserve the vendor’s exclusive responsibility when the buyer’s modifications satisfy provider-role conditions.
The trap
Separate the procurement event from later conduct that may change statutory role allocation.

How to remember it

Substantial modification and changed intended purpose can defeat the assumption that the purchaser has deployer-only duties.

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