What are actor roles under the EU AI Act?
The EU AI Act assigns obligations based on the actor role an organization holds — provider, deployer, importer, or distributor — not just by the AI system it uses. Understanding which role applies determines what the organization must actually do.
A provider develops or places an AI system on the market. A deployer uses it under its own authority. An importer brings a non-EU system into the market. A distributor makes it available in the supply chain. Each role carries distinct governance obligations, and a single organization may hold multiple roles for different systems.
Key points
- Actor role determines obligations. The same AI system may require different governance depending on whether the organization is provider or deployer.
- Actor-role assessment must be completed before obligations can be assigned. A risk classification without actor-role context is incomplete.
- An organization can shift from deployer to provider if it substantially modifies a system, places it on the market under its own name, or changes its intended purpose.
- Deployers are not passive users. Article 26 assigns them direct obligations for oversight, transparency, monitoring, and evidence management.
- The actor-role determination must be documented as part of the screening record. It is a governance decision, not an assumption.
Why it matters
Many organizations assume compliance is primarily a provider problem. It is not. Deployers face their own obligations, and the boundary between provider and deployer can shift based on how a system is customised or repurposed. A wrong actor-role assumption leads to wrong obligation mapping, which creates an evidence gap that surfaces at audit. Structured actor-role assessment prevents this.
How EAB approaches this
EAB includes a dedicated Actor Role Assessment as part of the screening process. The assessment evaluates how the organization relates to each AI system — development, deployment, import, or distribution — and documents the result as part of the governed record. The actor role feeds directly into the Obligation Matrix, ensuring that the correct obligations are assigned based on role, not assumption.