Governance

Developer

Entity that creates or substantially modifies AI systems.

How the laws define this

AI regulation universally identifies a developer as any natural or legal entity responsible for the technical design, coding, building, or training of an artificial intelligence system or model. Regulatory frameworks consistently place upstream obligations on developers, requiring them to manage training datasets, produce technical documentation, perform safety testing, and conduct risk assessments before deployment. The main point of divergence centers on whether developer status depends on commercial market activity or purely on technical creation. Legislation such as Colorado SB24-205, Connecticut SB 2, Senate Bill 26-189, and the High-Risk Artificial Intelligence Developer and Deployer Act ties developer status to doing business within a jurisdiction or commercially offering, selling, or leasing systems. In contrast, frameworks like the Voluntary AI Safety Standard (VAISS), Israel’s Policy on Artificial Intelligence Regulation and Ethics, and the Code of Ethics in the Field of Artificial Intelligence apply the developer label to any entity performing technical tasks like model construction, data preparation, or maintenance, regardless of commercial intent.

Synthesised from the 35 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 10 of the 35 instruments that define this term; all are listed under Definitions below.

JurisdictionInstrumentStatusWhat is distinctive
Colorado, United StatesColorado SB24-205 — Consumer Protections for Artificial Intelligence ActRepealedAdds upstream obligations like producing documentation, disclosing known risks, and enabling discrimination testing by deployers.
California, United StatesCalifornia AB 2013 — Generative Artificial Intelligence: Training Data TransparencyIn ForceLimits to generative AI systems or services, with obligations to publish and maintain training data disclosures.
European UnionAssessment List for Trustworthy Artificial Intelligence (ALTAI) — self-assessment toolIn ForceIncludes those making technical and design choices affecting system behaviour, expecting evidence of decisions, testing, and mitigations in self-assessment.
CanadaImplementation Guide for Managers of Artificial Intelligence Systems (Innovation, Science and Economic Development Canada)In ForceDistinguishes from managers who handle operational deployment, access, and production monitoring.
QatarPrinciples and Guidelines for Ethical Development and Deployment of Artificial Intelligence (MCIT)In ForceIncludes dataset selection and model validation activities as part of design, creation, training, and technical development.
United Arab EmiratesAI Ethics Self‑Assessment Tool (beta)In ForceIncludes making design decisions, selecting data, and implementing technical controls during development of the AI model or pipeline.
Saudi ArabiaAI Adoption Framework (SDAIA)In ForceAdds responsibility for maintaining AI models and collaborating with deployers to meet conformity expectations.
AustraliaAI Ethics Framework (Australia) / Australia’s AI Ethics PrinciplesAdoptedEmphasizes embedding ethical and governance considerations during technical design, documentation, and testing.
EthiopiaNational Artificial Intelligence PolicyIn ForceIncludes dataset selection and training processes, expecting cooperation with regulators.
MalaysiaNational AI Action Plan 2026-2030In ForceAdds producing model documentation and participating in pre-deployment testing and certification.

What it triggers

  • In Colorado, developers bear upstream obligations such as producing documentation, disclosure of known risks, and enabling discrimination testing by deployers.source
  • In California, developers bear the statutory obligations to publish and maintain required training data disclosures.source
  • In Colorado, developers must mitigate algorithmic discrimination and conduct impact assessments.source
  • Under the Assessment List for Trustworthy Artificial Intelligence (ALTAI), developers are expected to provide evidence of design decisions, testing and mitigations in the self-assessment.source

Definitions (36)

The natural or legal person (or organisation) responsible for the design, development, training, testing, or modification of an AI system, including creation of models, datasets and associated technical specifications. Developers bear obligations related to risk assessment, documentation, testing, and supplying information to downstream deployers and regulators.

A person or organization that designs, builds or trains AI models and is responsible for choices about model architecture, training data and development processes; distinguished from deployers and end‑users for the purposes of assigning responsibilities and obligations.

An entity that designs, builds, trains or maintains AI models or system components and that provides technical artefacts, documentation and provenance information to support deployers' risk assessments and supply-chain transparency obligations under VAISS.

Any person, partnership, state or local government agency, or corporation that creates, codes, produces, or substantially modifies a generative AI system or service; developers bear the statutory obligations to publish and maintain required training data disclosures.

Any person doing business in Colorado that develops or intentionally and substantially modifies an AI system, and that bears upstream obligations such as producing documentation, disclosure of known risks, and enabling discrimination testing by deployers.

An entity that creates, trains, or designs AI models and is responsible for model development tasks (including dataset selection and training processes); developers are expected to produce documentation, conduct required assessments, and cooperate with regulators as set out in the Policy.

The natural or legal persons responsible for creating, designing or training an AI system, including those who make technical and design choices that affect system behaviour; developers are expected to provide evidence of design decisions, testing and mitigations in the ALTAI self-assessment.

An entity responsible for designing, training, or otherwise creating AI-based systems, including those who prepare data, develop models, or set system objectives; developers are assigned obligations for documentation, risk mitigation, and accountability throughout the AI lifecycle.

An entity defined by the Plan that is responsible for designing, building or training an AI system, including creating model architectures, training datasets and associated development artifacts. Developers are identified as primary actors for producing model documentation and participating in pre-deployment testing and certification where applicable.

A natural or legal person (or entity) responsible for the design, creation, training and initial development of an AI system, including preparation of required documentation (e.g., model cards, impact assessments) and initial conformity demonstrations as mandated by the Bill.

An entity (individual or organisation) that designs, builds, or trains an AI model or system and is responsible for development decisions, documentation, testing, and ensuring compliance with applicable standards and obligations.

An individual or legal entity that designs, develops, trains, modifies or prepares an AI system for deployment, and that bears responsibility for ensuring the system meets safety, documentation, testing and legal compliance obligations established by the bill.

Teams or organisations that design, build, train, or fine‑tune AI models and are responsible for implementing technical controls, conducting testing (safety, bias, robustness), maintaining documentation, and cooperating with model owners on risk mitigation and compliance.

An entity (e.g., organisation or research group) responsible for designing, building or training AI models and associated components; distinguished from providers and deployers and typically accountable for aspects like model documentation, safety testing and providing provenance information.

Any natural or legal person involved in the design, training, testing, or maintenance of AI systems, responsible for implementing lifecycle controls (data governance, validation, documentation) in line with the Standards.

A party responsible for creating, training or otherwise preparing models and datasets; developers are distinguished from managers who make operational deployment decisions and manage access and monitoring in production.

A person, team, or organization responsible for the technical design, training, and creation of AI models and systems, including choices about data, model architecture and algorithmic configuration. Developers are distinct from deployers and operators and are accountable for producing documentation and technical artefacts required by the Policy.

A natural or legal person defined as responsible for the creation and training of AI models, who must perform risk and impact assessments, maintain technical documentation, implement privacy-by-design and security measures, and retain compliance packs as required by the bill.

The party or parties primarily responsible for the design, coding, and initial creation of an AI system. Developers are identified as potential actors who may be held liable under product liability principles if defects in design, construction, or instructions for use proximately cause harm.

The organisation or individual responsible for the design, creation, training and technical development of AI models and systems, including dataset selection and model validation activities as defined in the Guidance.

The organisation or team responsible for creating, training, or producing the AI model or pipeline, including making design decisions, selecting data and implementing technical controls during development.

Any person who develops or makes substantial modifications to an artificial intelligence system, intending to conduct business in the state.

Any natural or legal person who develops, or has an artificial intelligence system developed, with the intention of placing it on the market or putting it into service under their own name or trademark. This includes entities that significantly modify an existing AI system.

A person or entity that creates, codes, or programs a companion artificial intelligence chatbot for public or commercial use.

The entity or person that creates, develops, or provides an automated decision-making technology to a deployer.

Any person or entity that designs, develops, or trains an artificial intelligence system.

An entity doing business in Colorado that develops or substantially modifies a high-risk AI system.

A developer is any person doing business in Colorado who develops, offers, sells, leases, licenses, or otherwise makes commercially available a covered Automated Decision-Making Technology. This also includes individuals who develop components or substantially modify an ADMT.

Any person doing business in Colorado that develops, offers, sells, leases, licenses, or otherwise makes commercially available a covered ADMT, including individuals who develop components or substantially modify such technology.

An entity responsible for the creation or significant alteration of an AI system. Developers are subject to duties of reasonable care to protect consumers from known or foreseeable risks of algorithmic discrimination arising from their systems' intended uses.

An organization doing business in Virginia that offers, sells, leases, gives, or otherwise makes high-risk AI systems available to deployers in Virginia, including any person who intentionally and substantially modifies an existing high-risk AI system.

Entities or individuals responsible for designing, training and building AI models and systems. The interim response applies obligations and expectations (e.g., testing, documentation, governance) across the lifecycle to developers as actors who shape system behaviour and risk.

Entities (companies, research organisations, teams or individuals) involved in designing, training, testing or otherwise producing systems based on artificial intelligence, responsible for adopting recommended practices such as risk assessments, documentation and appointing internal ethics officers under the Code.

Organisations or teams that design, build, train and maintain AI models, and which are responsible for producing model documentation, supporting validation and testing, and collaborating with deployers to meet conformity expectations.

Entities that design, build or train AI systems and are responsible for technical design choices, documentation, testing and embedding ethical and governance considerations during development.

A person, partnership, state or local governmental agency, corporation, or deployer that designs, codes, substantially modifies, or otherwise produces a clinical decision support system for commercial or public use. Developers must make reasonable efforts to identify and mitigate biased impacts and provide documentation.

Not to be confused with

AI developer/provider

AI developer/provider includes entities that also deploy or offer AI products or services, while developer focuses solely on creation or modification.

Provider / Developer

Provider / Developer emphasizes designing or creating AI systems and models without distinguishing deployment roles.

Questions and answers

What obligations do developers have under Colorado SB24-205?

Developers doing business in Colorado bear upstream obligations such as producing documentation, disclosure of known risks, and enabling discrimination testing by deployers. The act requires developers of high-risk AI systems to mitigate algorithmic discrimination and conduct impact assessments.

Who is a developer under California's AB 2013?

Any person, partnership, state or local government agency, or corporation that creates, codes, produces, or substantially modifies a generative AI system or service. Developers must publish and maintain required training data disclosures.

What does ALTAI expect from developers?

The natural or legal persons responsible for creating, designing or training an AI system, including those who make technical and design choices that affect system behaviour. Developers provide evidence of design decisions, testing and mitigations in the ALTAI self-assessment.