Reassess provider and deployer roles against | AIGP
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Reassess provider and deployer roles against: What does the evidence support?

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

Substantial modification and changed intended purpose require contextual reassessment; contract labels alone cannot settle provider or deployer status.

The question

In the European Union, a customer-service company deploys a vendor’s applicable high-risk system under the vendor’s stated purpose, then substantially modifies it and changes the intended purpose. The contract calls the company only a buyer, while operational evidence shows the modified system is marketed under the company’s service. What does the evidence support?

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  1. The contract alone fixes the company’s role as buyer.
    Commercial agreements do not override statutory role analysis when substantial modification or changed intended purpose may trigger different responsibilities.
  2. Reassess provider and deployer roles against the modification and purpose. ✓
    The evidence requires contextual role analysis because own modifications and changed intended purpose may affect provider responsibilities.
  3. The vendor remains solely responsible after every customer modification.
    A substantial modification or changed intended purpose can affect responsibilities, so vendor responsibility is not automatically exclusive.
  4. Assign every provider and deployer duty to both companies.
    The EU AI Act distinguishes roles and duties; assigning every obligation to both parties ignores the context-specific allocation.
The trap
Treat contractual labels as evidence, not conclusions; assess statutory roles from conduct, purpose, and modification.

How to remember it

Substantial modification and changed intended purpose require contextual reassessment; contract labels alone cannot settle provider or deployer status.

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