Direct answer
Are we a provider or a deployer under the AI Act?
You describe: You want to determine your organisation’s role per AI use case, because the role determines the duty list. Likely role: role determination per use case.
This applies now
- Article 50: transparencyApplicable
- Article 4: AI literacyApplicable
Coming up
- Annex III: high-risk AIfrom 2 December 2027
The provider develops an AI system (or has it developed) and places it on the market under its own name; the deployer uses it under its own authority. The same organisation can hold a different role per system, and whoever substantially modifies a system or offers it under its own brand can still become a provider. Record the role per system in the register.
Your first actions
- Classify the use case and document the outcome. Assess Article 5, Article 6 and Annex III in that order and document purpose, context and any Article 6(3) exception.
- Implement the applicable disclosure, marking or label. First determine which paragraph of Article 50 applies, then implement the specific transparency measure.
- Take role- and context-specific AI literacy measures. Determine for each role, system and context which combination of instruction, guidance, practice or training is appropriate.
Record this
- Article 6 and Annex III classification record
- Transparency implementation record
- AI literacy measures record
General interpretation, not legal advice. Checked against Regulation (EU) 2024/1689 and the Digital Omnibus (EU) 2026/1744; the official source remains authoritative.
Full map for your situationFollow-up questions
Execution
Record the classification in an AI register
A classification without a register and ownership is not demonstrable. Embed AI guides classification, register and reassessment in a fixed approach.
See the Embed AI approach