The supplier remains provider: What is the clearest classification?
Purchasing and using a supplier’s unchanged system generally leaves the supplier provider and makes the office deployer.
The question
A university research office buys an admissions-support system from a supplier. Under the EU AI Act, duties apply, and the office merely uses it internally without changing its name or intended purpose. What is the clearest classification?
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- Both parties become providers whenever research administration uses high-risk software.High-risk use creates relevant duties but does not automatically transform every participating organization into a provider.
- The office becomes provider only after signing a broader vendor oversight agreement.An agreement may clarify responsibilities but does not itself create provider status under the statutory role conditions.
- The office is the provider because it selected the supplier.Selecting or purchasing a system does not automatically make the research office its provider under the EU AI Act.
- The supplier remains provider; the office acts as deployer in use. ✓The supplier remains provider absent an own-name placement or relevant modification, while the office uses the system as deployer.
The trap
Do not infer provider status merely from buying, selecting, or supervising a system. How to remember it
Purchasing and using a supplier’s unchanged system generally leaves the supplier provider and makes the office deployer.
How many of these would you get right?
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