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What Your Customers Are Required to Ask For
Where a vendor's product is a high-risk system, or sits inside one, customers' questions follow from duties the AI Act places on them, and several answers need evidence the product does not yet emit. Which provision governs depends on three configurations: provider to deployer, governed by Articles 13 and 26; supplier into a customer's high-risk system, where Article 25(4) requires a written agreement; and neither. Vendors should establish each product line's configuration, publish a versioned fact sheet and the right schedules, and start decision-level logging early, because its lead time exceeds the sales cycle.
Key findings
- Which AI Act provision governs a customer's questions depends on which of three configurations a product line is in, and many vendors occupy more than one across a portfolio.
- Article 25(4) applies only where the vendor supplies into a customer's high-risk system; a provider that cites it to a deployer has cited an article that does not govern the relationship.
- A customer that rebrands, substantially modifies or repurposes a system can become its provider under Article 25(1), and the vendor then owes cooperation under Article 25(2).
In the paper
- The question arrives through procurement
- Which provision governs depends on the role you hold
- Your customer can become the provider without deciding to
- Upstream documentation does not answer the question
- Buyers have already written the questions down
- Twelve fields, three lead times
- The first hour
Michael Clark
Chief Executive Officer, Standard Intelligence
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