
AI Agents: When a Deployer Becomes a Provider
AI agents under the AI Act: when customisation, integration or rebranding triggers reclassification from deployer to provider under Article 25. Decision table, compliance checklist and first 5 actions.

AI agents under the AI Act: when customisation, integration or rebranding triggers reclassification from deployer to provider under Article 25. Decision table, compliance checklist and first 5 actions.

Misinformation is circulating about deployer obligations. This post sets the record straight: definition of deployer (Art. 3(4)), actual obligations (Art. 26 for high-risk only), official materials on transparency (Art. 50), the Commission’s position on AI agents (AI Act Service Desk FAQ), correct deadlines (Art. 113), actual penalties (Art. 99) and an operational framework for businesses and professionals.

Chatbots, adaptive tutoring, proctoring, guidance systems: a practical matrix to understand which AI tools used in European schools are potentially high-risk under the AI Act and what obligations follow.