Your role: Do you share the assistant?

Why does your role matter?

The AI Act is largely designed as a product safety regulation. This means that responsibility and obligations are distributed based on where the organisation sits in the AI value chain. This is a deliberate distinction to place responsibility where it can best be managed:

• Providers bear the heaviest responsibility and must document that the AI system itself is safe before it is made available (design, technical documentation, testing, CE marking).
• Deployers have a responsibility directed at the specific use of the system in everyday operations (ensuring human oversight, following instructions for use, and safeguarding residents’ rights).

Your role under the AI Act is determined primarily by whether you share the assistant outside your own organisation:

• Deployer: You are a deployer if your municipality uses the assistants exclusively internally.
• Downstream provider: You become a downstream provider if your municipality shares a pre-built assistant with other municipalities. (You then take on a “Provider” responsibility for what you share.)
  • Note: By “sharing” we mean giving another municipality access to an assistant you have built, which they have not built themselves on the platform. If another municipality builds their own assistant based on your instructions/prompts (for example via “Assistant Library”), this does not count as sharing the system, and you remain a deployer.