# Deployers, distributors and importers must assume provider duties when they rebrand or substantially modify high-risk AI

- **Record type**: Obligation
- **Instrument**: Regulation (EU) 2024/1689 — Artificial Intelligence Act
- **Jurisdiction**: European Union
- **Category**: governance_accountability
- **Binding**: Yes
- **Applies from**: 2026-08-02
- **Provision**: Article 25(1) and 25(2)

## What the duty requires

A distributor, importer, deployer or other third party is treated as the provider of a high-risk AI system, with all Article 16 duties, if it puts its own name or trademark on a system already on the market, makes a substantial modification to a high-risk system that stays high-risk, or changes the intended purpose of a system so that it becomes high-risk. The original provider then ceases to be provider for that system but must cooperate and supply the information and access needed for the new provider to comply.

## What an organisation does about it

Add a reclassification check to change control so that white-labelling, fine-tuning or repurposing a high-risk system triggers the provider workstream.

## Controls that meet this duty

- AI system inventory and classification (supports): https://aipolicytracker.org/controls/ai-system-inventory
- Contractual allocation of AI duties across the supply chain (supports): https://aipolicytracker.org/controls/contractual-allocation-of-ai-duties
- Model release and change-management gate (satisfies): https://aipolicytracker.org/controls/model-release-and-change-management-gate

## Parent instrument

- Regulation (EU) 2024/1689 — Artificial Intelligence Act
  - Record: https://aipolicytracker.org/policies/eu-ai-act
  - Context file: https://aipolicytracker.org/policies/eu-ai-act.md

## Provenance

- **Record page**: https://aipolicytracker.org/obligations/eu-ai-act-art-25-value-chain-becoming-provider
- **Official source**: https://eur-lex.europa.eu/eli/reg/2024/1689/oj
- **Provision**: Article 25(1) and 25(2)
- **Review status**: pending review
- **Confidence**: high
- **Facts last confirmed**: never confirmed against the official source
- **Retrieved**: 2026-09-24
- **Licence**: https://creativecommons.org/licenses/by/4.0/

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