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Article 25: Responsibilities along the AI value chain

Article 25 states that a distributor, importer, deployer or third party is considered a provider if they place the AI system on the market under their own name, modify the intended purpose, or make a substantial modification.

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Praxikon tracks Article 25 (Responsibilities along the AI value chain) under the EU AI Act, citing the source for every statement.

EU Official:
Title III: High-Risk AI Systems

Official text

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Source: EUR-Lex, Regulation (EU) 2024/1689. Text reproduced verbatim.

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Decision tree

Do you become the provider of a high-risk AI system?

Article 25 shifts the provider role to whoever puts someone else’s system under their own name, substantially modifies it or deploys it for another purpose. The outcome is always: you become the provider of a high-risk system, with the obligations of Article 16.

Question 1 · Art. 25(1)

Are you a distributor, importer, deployer or other third party in relation to an AI system that someone else has already placed on the market or put into service?

Full diagram
  1. 1

    Are you a distributor, importer, deployer or other third party in relation to an AI system that someone else has already placed on the market or put into service?

    Art. 25(1)

    • Yes → Question 2
    • No, we developed it ourselves → Outcome A
  2. 2

    Do you put your name or trademark on a high-risk AI system already placed on the market or put into service?

    Art. 25(1)(a)

    • Yes → Outcome B
    • No → Question 3
  3. 3

    Do you make a substantial modification to a high-risk AI system, such that it remains a high-risk system?

    Art. 25(1)(b) · Art. 3(23)

    • Yes → Outcome C
    • No → Question 4
  4. 4

    Do you modify the intended purpose of an AI system that has not been classified as high risk, including a general-purpose AI system such as a general chatbot?

    Art. 25(1)(c)

    • Yes → Question 5
    • No → Question 6
  5. 5

    Does your new purpose make the system a high-risk system under Article 6, for example because you use it to select job applicants or assess creditworthiness?

    Art. 25(1)(c) · art. 6

    • Yes → Outcome D
    • No → Outcome E
  6. 6

    Is the high-risk system a safety component of a product under Section A of Annex I, placed on the market or put into service under your name or trademark as product manufacturer?

    Art. 25(3)

    • Yes → Outcome F
    • No → Outcome G

Outcome A · Check further

You are probably already the provider

Whoever develops an AI system or has it developed and places it on the market or puts it into service under their own name is the provider. Article 25 is then not needed. Check with Article 6 whether the system is high risk.

Art. 3(3) · art. 6

Outcome B · Applies

You become the provider through your own name or trademark

You take on the provider obligations of Article 16. The regulation leaves contractual arrangements that allocate the obligations differently unaffected. Record such an allocation in writing, but do not assume that it releases you from your obligations towards the supervisory authority: the text is not explicit on that. The initial provider cooperates with you and provides the necessary information, documentation and technical access (paragraph 2).

Art. 25(1)(a) · Art. 25(2) · art. 16

Outcome C · Applies

You become the provider through a substantial modification

You take on the obligations of Article 16 and the modified system must undergo a new conformity assessment (Article 43(4)). The initial provider is no longer considered the provider of that system, but must cooperate closely: documentation, known limitations and failure modes, and targeted technical access for testing.

Art. 25(1)(b) · Art. 25(2) · art. 16 · Art. 43(4)

Outcome D · Applies

You become the provider through a new intended purpose

The new purpose makes the system high risk and you are the provider, with the obligations of Article 16. If the initial provider clearly specified that the system is not to be changed into a high-risk system, it does not have to hand over documentation. For Annex III the requirements apply from 2 December 2027.

Art. 25(1)(c) · Art. 25(2) · art. 16 · art. 113 onder c

Outcome E · Does not apply

No shift under Article 25

If the system stays outside Article 6 after your change of purpose, you do not become the provider of a high-risk system. If you do put the system into service under your own name, you may be the provider of an ordinary AI system, with for example the obligations of Article 50.

Art. 25(1)(c) · Art. 3(3) · art. 50

Outcome F · Applies

As product manufacturer you are the provider

The product manufacturer is considered the provider of the high-risk system and takes on the obligations of Article 16. For systems under Annex I the requirements apply from 2 August 2028.

Art. 25(3) · art. 16 · art. 113 onder c

Outcome G · Does not apply

You do not become the provider through Article 25

You keep your own role. If you supply as a third party a system, model, tool, service, component or process used or integrated in a high-risk system, you and the provider specify in writing which information, technical access and assistance you provide (paragraph 4). That does not apply if you make tools, services, processes or components, other than general-purpose AI models, accessible to the public under a free and open-source licence.

Art. 25(4)

A decision tree simplifies. If you are unsure at a question, read the provision or have it assessed. Checked against the legal text on 1 October 2026.

Related enforcement

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Frequently asked questions

When is someone considered a provider under Article 25 AI Act?+
Article 25 states that a distributor, importer, deployer or third party is considered a provider if they place the AI system on the market under their own name, modify the intended purpose, or make a substantial modification.
What are the consequences of a role change in the AI value chain?+
Anyone classified as a provider under Article 25 assumes all provider obligations under Article 16, including conformity assessment and registration.
What documentation does Article 25 of the AI Act require?+
Article 25 of the AI Act requires that relevant documentation is maintained as part of the compliance process. This may include technical documentation, instructions for use, logs or declarations of conformity, depending on the classification of the AI system.

Connections

What connects to Article 25 AI Act

Themes where this returns

The counterpart in the other law

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