AI Deployer

The EU AI Act distinguishes between AI providers (companies like OpenAI, Stability AI, and Midjourney that build the models) and AI deployers (organizations that use those models in their operations). This distinction matters because each role carries different obligations under the regulation.

For creative agencies, deployer obligations include: ensuring AI systems are used in accordance with their instructions, implementing human oversight measures, monitoring AI system operations for risks, and maintaining logs of AI system use. Agencies that fine-tune models or build custom workflows may cross into provider territory, triggering additional requirements. Understanding your classification—deployer, provider, or both—is the first step in building an effective compliance programme.