Article 25: Responsibilities Along the AI Value Chain
provider · high risk · Article 25
Article 25 is the re-qualification trigger: it defines when a distributor, importer, deployer, or third party becomes a provider of a high-risk AI system and inherits the full provider obligations under [Article 16](/en/ai-act-guide/article-16). This happens when they: (a) put their name or trademark on a system already placed on the market; (b) make a substantial modification; or (c) modify the system's intended purpose so it becomes high-risk. The original provider is released from Article 16 duties once the new provider is properly identified. Critical for deployer due diligence, any modification beyond normal use may shift obligations.
How to satisfy it: Include Article 25 analysis in all change control and modification approval workflows.
Article 25 on EUR-Lex · as of 2026-08-03 · Regulation (EU) 2024/1689 as amended by Regulation (EU) 2026/1744