Article 25: When a Deployer Becomes a Provider
Article 25 sets out when another actor in the value chain — typically a deployer — is treated as the provider and takes on the full Article 8 to 22 obligation set: when it puts its own name or trademark on a high-risk system, when it makes a substantial modification to an already placed system, or when it changes the intended purpose of a system in a way that makes it high-risk.
- 02 Dec 2027 Practically coupled to the Annex III high-risk applicability date
- Assess whether placing your own name or trademark on a system triggers provider status under Article 25.
- Assess whether a substantial modification to an already-placed system triggers a role change to provider.
- Assess whether changing a system's intended purpose brings it within a high-risk use case and triggers provider status.
- If a role change is triggered, assume the full provider obligation set under Articles 8 to 22, including conformity assessment and CE marking.
- Document the substantial-modification or purpose-change assessment even where the conclusion is that no role change occurred.
- Change documentation and role-classification assessment
Companies often assume fine-tuning or integrating a third-party model can never make them a provider; a substantial modification or a purpose change toward an Annex III use case can shift the full provider obligation stack onto them even though they did not build the base model.
What regulators published on Art. 25
- Loading from the public feed…
- Regulation (EU) 2024/1689 on EUR-Lex
- Look for Article 25
- Deadline changes and the acts behind them
Get told when Art. 25 moves.
Deadlines under this regulation have already shifted once in 2026. A signed webhook, a REST API and an MCP server carry the same record this page is built from, so your systems learn about the next change without anyone re-reading the text. Free during the beta.
Get free accessInformational content only. Not legal advice and not a substitute for qualified counsel. Dates reflect Regulation (EU) 2026/1744 as of 04 Aug 2026.