DepthThe conclusion and your first steps
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
- Justify the Article 6(3) exception against each individual condition. Name which of the four Article 6(3) conditions you invoke, with facts, and separately justify why the system poses no significant risk of harm to health, safety or fundamental rights and does not materially influence the outcome of decision making.
- 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.
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 situation