AI Act classifier: your role and your obligations, with dates

They are the four roles («operators») defined in art. 3 of Regulation (EU) 2024/1689. The provider (art. 3.3) develops the system or model and places it on the market under its own name or trademark. The deployer (art. 3.4) uses it under its own authority, except for personal non-professional use. The importer (art. 3.6) places on the EU market a system bearing a third-country trademark. The distributor (art. 3.7) makes it available in the Union without being the provider or the importer. Each one has different obligations.

Under art. 113 as currently in force: Chapters I and II (general provisions, AI literacy and prohibited practices) have applied since 2 February 2025. Chapter III Section 4, Chapter V (general-purpose models), Chapter VII (governance) and Chapter XII (penalties, except art. 101) have applied since 2 August 2025. 2 August 2026 remains the general date of application for the rest of the Regulation, including the transparency obligations of art. 50. On 2 December 2026 the two new prohibitions in art. 5(1), first subparagraph (points (ba) and (bb)) and paragraphs 1a and 1b become applicable; on that same date — as a separate matter — falls the deadline under the new art. 111(4) for providers of systems generating synthetic content already on the market before 2 August 2026 to comply with art. 50(2). And Chapter III, Sections 1, 2 and 3 — the requirements for high-risk systems and the obligations of their providers and deployers — with the exception of art. 6(5), apply from 2 December 2027 for the systems in art. 6(2) and Annex III, and from 2 August 2028 for those in art. 6(1) and Annex I. Those last two dates are set by Regulation (EU) 2026/1744 (the digital omnibus on AI), in force since 27 July 2026.

Stop its development, placing on the market or use: the prohibition in art. 5 has been in force since 2 February 2025 and admits no compliance plan. Breaches are fined up to 35 million euros or 7% of worldwide annual turnover (art. 99.3).

Yes. By using a third party's AI system under your own authority, you act as the deployer of THAT system (art. 3.4), with obligations of your own: AI literacy for your staff (art. 4, in force since 2 February 2025) and, if you expose the output to people or publish it, the transparency duties of art. 50 (disclosing the AI interaction, marking synthetic content) from 2 August 2026.

It depends on what is breached (art. 99): up to €35M or 7% of worldwide turnover for the prohibited practices in art. 5; up to €15M or 3% for breaching the other obligations (provider, importer, distributor, deployer, transparency); up to €7.5M or 1% for supplying incorrect or misleading information to the authorities. For SMEs and start-ups, art. 99.6 allows the fine to be set by the percentage or by the fixed amount, whichever is lower: its wording is «shall be up to», that is, a power of the authority and not an automatic right to the lower figure. Work out the exact amount for your situation in the AI Act fine calculator.

No. It is indicative: it does not analyse your actual technical documentation, your contract with AI providers or whether your model exceeds the systemic risk threshold. Check your case with the AI Act Compliance service from Summum Consultoría (the diagnosis and the compliance plan) or with Summum IA (the technical layer: traceability, bias assessment, Annex IV) before acting.