Economic Operators & Roles
Roles Under the AI Act
The AI Act distinguishes various roles in the AI value chain, analogous to the CRA model of economic operators:
Provider — Art. 3(3)
A natural or legal person that develops an AI system or has it developed and places it on the market or puts it into service under its own name or trademark.
Obligations (summary):
- Conformity assessment before placing on the market
- Technical documentation + QMS
- CE marking + EU declaration of conformity
- Registration in EU database
- Post-market monitoring
- Corrective actions and reporting obligations
Deployer — Art. 3(4)
A natural or legal person that uses an AI system in a professional capacity (not the end consumer).
Obligations (summary):
- Use in accordance with the intended purpose as per provider instructions
- Ensure human oversight
- Ensure input data quality
- Retain logs (minimum 6 months)
- Report risks and incidents to the provider
- Inform workers about AI use (for high-risk)
Importer — Art. 23
Places AI systems from third-country providers on the EU market. Must ensure that the provider has carried out the conformity assessment.
Distributor — Art. 24
Makes AI systems available on the EU market without being a provider or importer. Due diligence obligations regarding conformity.
BAUER GROUP Role Allocation
| Scenario | Role | Obligation Catalogue |
|---|---|---|
| BAUER GROUP develops own AI system for customers | Provider | Full (Art. 16–21) |
| BAUER GROUP integrates third-party AI (e.g. OpenAI, Claude) into own product | Provider (Art. 25) | Full — whoever distributes AI under their own name assumes provider obligations |
| BAUER GROUP uses AI tools internally (e.g. Claude, GitHub Copilot) | Deployer | Reduced (Art. 26) |
| BAUER GROUP distributes a partner's AI system | Distributor | Due diligence obligations (Art. 24) |
Important: Art. 25 – Transfer of Responsibility
Whoever places an AI system on the market under their own name becomes the provider — even if they did not develop the system themselves. This also applies to substantial modifications to an existing system or a change of intended purpose of a high-risk system.
Authorised Representatives (Art. 22)
Third-country providers must appoint an authorised representative in the EU before placing on the market. For BAUER GROUP (established in Germany) this obligation does not apply to in-house developments.