Governance

AI Developer

Entity that designs and creates AI systems.

How the laws define this

Regulators uniformly view an AI developer as any actor that designs, builds, creates, or trains an artificial intelligence model or system, holding them responsible for technical standards, safety, risk management, and documentation. Divergence appears primarily in how broadly regulatory frameworks extend this classification across the system lifecycle and operational roles. Instruments like House Bill No. 7396, House Bill No. 7913, the AI Basic Act (Draft), and the Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems (PDPC) expand coverage to entities that fine-tune or substantially modify systems. Conversely, the G7 Hiroshima AI Process restricts focus to organizations developing advanced systems. Additionally, House Bill No. 7396 explicitly encompasses individual software engineers, data scientists, and commissioning organizations, whereas the Central Bank AI Guidelines and the Republic Unifying Meritocratic Performance Advancing Machine Intelligence by Eliminating Regulatory Interstate Chaos Across American Industry Act include implementation or ongoing system maintenance.

Synthesised from the 10 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 9 of the 10 instruments that define this term; all are listed under Definitions below.

JurisdictionInstrumentStatusWhat is distinctive
TaiwanTaiwan Artificial Intelligence Basic ActIn ForceExplicitly includes modifying AI systems and specifies responsibilities for creating models, datasets, technical documentation, and meeting development-phase obligations.
SingaporeAdvisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems (PDPC)In ForceEncompasses organizations, teams, or vendors building, training, or fine-tuning AI models, with emphasis on data protection-by-design, provenance documentation, and testing.
Doha, QatarCentral Bank AI GuidelinesIn ForceLimits to entities and professionals focused on designing, developing, and implementing AI systems and applications in a financial context.
JapanAI Utilization Guidelines (Practical Reference for AI Utilization)AdoptedHighlights responsibilities for choices about algorithms, architectures, training procedures, and evaluation criteria, plus ensuring robustness, explainability, and proportional testing.
United StatesThe Republic Unifying Meritocratic Performance Advancing Machine Intelligence by Eliminating Regulatory Interstate Chaos Across American Industry ActProposedIncludes maintaining the underlying architecture and datasets of AI systems.
EcuadorDraft Organic Law for the Regulation and Promotion of Artificial IntelligenceUnder ReviewAdds responsibilities for safety and transparency by default, risk assessments, documentation, conformity with standards, and cooperating with authorities.
PhilippinesHouse Bill No. 7396 (Artificial Intelligence Development and Regulation Act)Under ReviewIncludes software engineers, data scientists, research teams, and organizations commissioning AI development as primary actors.
G7Hiroshima Process International Guiding Principles for Organizations Developing Advanced AI Systems and International Code of Conduct for Organizations Developing Advanced AI SystemsAdoptedSpecifies organizations developing advanced AI systems including foundation models, with risk management, testing, documentation, and mitigation practices.
PhilippinesHouse Bill No. 7913 (Artificial Intelligence Regulation Act - AI Bill of Rights)WithdrawnEmphasizes embedding ethical standards and safety-by-design throughout the development lifecycle.

What it triggers

  • In Taiwan, AI developers must meet development-phase obligations under the Artificial Intelligence Basic Act.source
  • In Singapore, AI developers are responsible for implementing data protection-by-design, documentation of provenance, and testing practices.source
  • Under the Qatar Central Bank AI Guidelines, AI developers should follow governance standards, conduct risk assessments, and ensure human oversight.source
  • Under the G7 Hiroshima Process International Guiding Principles, organizations developing advanced AI systems should implement risk management, testing, documentation, and mitigation practices.source

Definitions (10)

Entities or persons who design, create, and produce AI systems and who are responsible for designing systems with safety and transparency by default, conducting risk assessments, providing required documentation, ensuring conformity with standards, and cooperating with regulatory authorities.

Any individual or entity engaged in designing, creating, training, or substantially modifying artificial intelligence systems, including software engineers, data scientists, research teams, and organizations commissioning AI development; identified as a primary actor responsible for ensuring systems meet technical, ethical, and regulatory requirements.

Entities that create, design, or substantially modify artificial intelligence systems, including those responsible for model architecture, training, and system specifications. Developers bear responsibilities for embedding ethical standards, safety-by-design, and documentation throughout the development lifecycle.

Individuals or organizations that design, develop, train or produce AI systems, bearing responsibilities to ensure systems meet the guidelines' ethical, technical and legal requirements during design, pre-deployment and operation.

Any organisation, team or vendor that builds, trains, fine-tunes or otherwise develops AI models and related systems, including in-house development teams and third‑party service providers. The Guidelines treat AI developers as key actors responsible for implementing data protection‑by‑design, documentation of provenance, and testing practices.

An entity (natural or legal) that designs, develops, trains, or modifies AI systems, responsible for creating models, datasets, and technical documentation, and for meeting development-phase obligations under the Act.

AI Basic Act (Draft)Definition 6 of 10

Entities and professionals who design, develop, and implement AI systems and applications.

Central Bank AI GuidelinesDefinition 7 of 10

The organization or individual that designs, trains, and maintains the underlying architecture and datasets of an artificial intelligence system.

Individuals or teams responsible for designing, building, training and validating AI models and systems, including choices about algorithms, architectures, training procedures and evaluation criteria. The Guidelines assign developers responsibility for ensuring robustness, explainability and appropriate testing proportional to risk.

AI Developers are organizations responsible for designing, developing, training, and maintaining advanced AI systems (including foundation models), and for implementing risk management, testing, documentation, and mitigation practices during development.

Not to be confused with

Technology Developers

Technology developers focus specifically on creating and maintaining foundational AI models, while AI developers cover broader designing, developing, training, or modifying of AI systems.

AI developer organisation

AI developer organisation is limited to entities that design, build, or maintain AI systems, whereas AI developer includes individuals, teams, and broader actors.

Model developer

Model developer is narrower, focusing on entities that create or fine-tune generative models, unlike the wider scope of AI developers handling full systems.

Questions and answers

Does AI developer include individuals or only organizations?

Several definitions explicitly include individuals, natural persons, teams, software engineers, data scientists, and professionals alongside organizations and legal entities.

What obligations do AI developers have under binding laws?

In Taiwan, they must meet development-phase obligations; in Singapore, implement data protection-by-design and testing; others are guidelines recommending practices.

Is modifying an AI system enough to make someone an AI developer?

Yes, definitions from Taiwan, Singapore, Philippines bills, and others explicitly include modifying, training, fine-tuning, or substantially modifying AI systems.