Compliance

Putting into Service

The supply of an AI system for first use directly to the deployer or for own use, marking when the system becomes operational.

Definition

Putting into Service is defined in the EU AI Act as "the supply of an AI system for first use directly to the deployer or for own use on the Union market for its intended purpose" (Article 3(11)). This represents the moment when an AI system becomes operational for its intended use.

Legal Significance:

  • Operational Trigger: Marks when the AI system begins actual use for its intended purpose
  • Deployer Obligations Begin: The deployer's responsibilities under the AI Act commence at this point
  • Distinct from Placing on Market: A system can be placed on the market (made available) but not yet put into service (activated for use)
  • Own Use: Includes situations where organizations develop and deploy AI systems internally without commercial distribution

Timing Considerations:

  • For commercial AI systems: Typically occurs after sale/delivery to the deployer
  • For internally developed AI: Occurs when the organization begins using the system for its intended purpose
  • For AI-as-a-Service: May occur when the service is activated for a customer

Compliance Requirements at Putting into Service:

  • Instructions for use must be provided to deployers
  • Required human oversight measures must be in place
  • Logging and monitoring capabilities must be functional
  • Any necessary registrations in the EU database must be completed

Sources

  • EU AI Act Article 3(11)
  • EU AI Act Recital 25