Compliance

Distributor

Any entity in the supply chain that makes an AI system available on the EU market without affecting its properties.

Definition

Distributor is defined in the EU AI Act as "any natural or legal person in the supply chain, other than the provider or the importer, that makes an AI system available on the Union market" (Article 3(7)).

Key Characteristics:

  • Part of the commercial supply chain but not the original provider
  • Not the entity that brings the AI system into the EU (that's the importer)
  • Does not modify the AI system in ways that affect its compliance
  • Makes AI systems available without producing or importing them

Distributor Obligations (Article 24):

  • Verification: Before making a high-risk AI system available, must verify that:
    • The provider has conducted the required conformity assessment
    • The system bears CE marking
    • The system is accompanied by required documentation and instructions for use
    • Provider and importer (if applicable) have complied with their obligations
  • Storage/Transport: While the AI system is under their responsibility, ensure storage and transport conditions do not jeopardize compliance
  • Corrective Action: If a system is not in conformity, must not make it available until brought into conformity, and inform the provider/importer and market surveillance authorities of non-compliance presenting a risk

Distinction from Other Roles:

  • Provider: Develops and places AI system on the market
  • Importer: Brings AI system from outside the EU
  • Deployer: Uses the AI system (end user)
  • Distributor: Intermediary that makes the system available commercially

Sources

  • EU AI Act Article 3(7)
  • EU AI Act Article 24