Governance

AI Value Chain

The sequence of actors involved in developing, providing, deploying, and using AI systems.

Definition

AI Value Chain refers to the sequence of actors, activities, and relationships involved in the development, provision, deployment, and operation of AI systems—from initial research through end-user interaction. The EU AI Act establishes distinct obligations for different value chain participants.

EU AI Act Value Chain Actors:

  • Provider (Article 3(3)): Develops or has AI system developed and places it on market under own name
  • Deployer (Article 3(4)): Uses AI system under their authority (except personal use)
  • Importer (Article 3(6)): Places non-EU provider's system on EU market
  • Distributor (Article 3(7)): Makes AI system available in supply chain
  • Authorized Representative (Article 3(5)): EU-based mandate holder for non-EU providers

GPAI Model Chain:

  • Upstream: Foundation model developers
  • Midstream: Fine-tuners and integrators
  • Downstream: Application developers and deployers

Obligation Distribution:

  • Each actor has specific obligations proportionate to their role
  • Information must flow through the chain (e.g., instructions for use)
  • Downstream actors can rely on upstream compliance representations
  • Modifications may shift actor classification

Related concepts: Provider, Deployer, Upstream Provider, Downstream Deployer

Sources

  • EU AI Act Article 25
  • Supply Chain Standards