Deployer, because it uses an AI system under its own: Under the EU AI Act, which operator role does the
Using a purchased AI system under one's own authority in a professional setting is the defining feature of the deployer role.
The question
A hospital purchases a high-risk AI diagnostic system from an external vendor and uses it in its clinical operations under its own authority, without modifying or rebranding it. Under the EU AI Act, which operator role does the hospital hold?
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- Deployer, because it uses an AI system under its own authority in the course of its professional activity ✓Correct: using a system under one's own authority in a professional context defines the deployer role.
- Provider, because it develops the AI system or has it developed and then markets it under its own name or trademarkPlausible, but the hospital did not develop or rebrand the system, so it is not the provider.
- Importer, because it is established in the EU and places a third-country party's AI system on the marketThe hospital is an end user, not the party placing a non-EU system on the market, so importer does not fit.
- Distributor, because it sits in the supply chain and makes the system available to others on the marketA distributor supplies the system onward, whereas the hospital uses it internally rather than supplying it.
The trap
Assuming any organization operating a high-risk AI system automatically counts as its provider. How to remember it
Using a purchased AI system under one's own authority in a professional setting is the defining feature of the deployer role.
How many of these would you get right?
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Every answer, right and wrong, comes with its own explanation.