Distributor
A company in the EU that passes an AI product along the supply chain to customers without changing it, like a reseller or marketplace.
The Simple Version
A company in the EU that passes an AI product along the supply chain to customers without changing it, like a reseller or marketplace.
Detailed Explanation
Distributors bear lighter obligations than providers or importers, but must verify that high-risk AI systems bear CE marking, that a declaration of conformity is available, and that the provider and importer have fulfilled their obligations. Distributors must not make available any AI system they have reason to believe does not comply with the Act. If a distributor modifies the system, including for a new market or use case, it assumes provider obligations for the modified version.
Key Characteristics
- No modification to the AI system in the supply chain
- Must verify CE marking and declaration of conformity before distribution
- Assumes provider obligations upon substantial modification
- Must cooperate with market-surveillance authorities on request
Why It Matters
App marketplaces, software resellers, and system integrators that bundle third-party AI capabilities into their offerings need clarity on whether they are distributors or providers to determine their compliance obligations.
Real-World Analogy
A bookshop that sells textbooks does not write or edit them, but it should refuse to stock books that are obviously pirated or labelled fraudulently, distributors of AI systems have an analogous duty of care.
Common Misconceptions
- Distributors can freely re-label or translate AI systems without becoming providers, any substantial modification, including localisation that changes core functionality, triggers provider obligations.
- Distributing AI as part of a broader service means the distributor has no obligations, the distributor obligations apply regardless of bundling.