AI Actors
Public authorities and private entities involved in AI development or deployment.
How the laws define this
Every cited framework establishes that AI actors encompass any individual, organization, or entity involved at any stage of the AI system lifecycle—from design and development to deployment and operation—who holds responsibilities for system governance, compliance, or impacts. The principal point of divergence is whether end users fall within scope. The UNESCO Recommendation on the Ethics of Artificial Intelligence, the Recommendation of the Council on Artificial Intelligence, and the Responsible Artificial Intelligence guidance for businesses explicitly classify users or end users as AI actors. In contrast, the Council of Europe Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law focuses on public authorities, private entities, vendors, and contracting public bodies without listing users, while the OECD Recommendation on Artificial Intelligence (AI Principles) limits coverage to entities playing an active role or materially influencing systems and their outcomes.
Synthesised from the 5 statutory definitions below. Each one is quoted in full, with its source.
How jurisdictions differ
What is distinctive in each definition, binding law in force first. Showing 4 of the 5 instruments that define this term; all are listed under Definitions below.
| Jurisdiction | Instrument | Status | What is distinctive |
|---|---|---|---|
| Council of Europe | Council of Europe Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law (CETS No. 225) | Awaiting Entry | Expands scope to include procurement, operation, governance, and explicitly names vendors, operators, contracting public bodies alongside developers and deployers. |
| OECD | Recommendation of the Council on Artificial Intelligence | In Force (Amended) | Broadens to those who materially influence AI systems and outcomes, without naming specific roles or limiting to lifecycle stages. |
| UNESCO | Recommendation on the Ethics of Artificial Intelligence | In Force | Includes researchers and end users alongside developers, deployers, operators, and emphasizes oversight and impacts across the full AI lifecycle. |
| New Zealand | Responsible Artificial Intelligence guidance for businesses | In Force | Adds suppliers explicitly and highlights responsibilities for governance, compliance, procurement, and operational decisions. |
Definitions (5)
Public authorities and private entities involved in the development, deployment, procurement, operation, or governance of AI systems — including developers, deployers, vendors, operators, and contracting public bodies — who bear responsibilities under the Convention.
Those who play an active role in the AI system lifecycle, including organizations and individuals that deploy, operate, design, develop, or otherwise materially influence AI systems and their outcomes.
Any individual or organization engaged at any stage of the AI lifecycle, including researchers, developers, deployers, operators, and end users, who have roles and responsibilities for the design, deployment, oversight, and impacts of AI systems.
Individuals, organisations, or other entities that play a role in the AI system lifecycle. This includes, but is not limited to, developers, deployers, operators, and users of AI systems.
Any party involved in the design, development, supply, deployment or use of an AI system — including developers, deployers, suppliers and users — who hold responsibilities for governance, compliance, procurement and operational decisions related to that system.
Not to be confused with
Responsible Party focuses on the person or entity bearing liability for AI-related harm, while AI Actors cover broader involvement in the AI lifecycle without specifying liability.
AI developers, deployers, and operators name specific roles in the lifecycle, whereas AI Actors encompass a wider range of public authorities and private entities involved.
Questions and answers
What entities count as AI Actors under the Council of Europe Convention?
Public authorities and private entities involved in development, deployment, procurement, operation, or governance of AI systems, including developers, deployers, vendors, operators, and contracting public bodies. They bear responsibilities under the Convention.
Does the OECD AI Recommendation apply to AI users?
Yes, it covers individuals and organizations that deploy, operate, design, develop, or materially influence AI systems, including users in some definitions.
Who has responsibilities in New Zealand's AI guidance?
Parties involved in design, development, supply, deployment, or use of AI systems, including developers, deployers, suppliers, and users, who hold duties for governance, compliance, procurement, and operations.
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