The Value Chain: Providers, Deployers, Importers, Distributors

Who owes what along the AI value chain — the Art 16 provider checklist, importer and distributor gatekeeping, the Art 25 role-switch traps, deployer duties under Art 26, and the fundamental rights impact assessment.

Content current as of 2026-09.

Lessons

1. Who is who: the five operators
2. The provider: Art 16 and the quality management system
3. Importers, distributors, and the obligation matrix
4. Art 25: when you become the provider
5. Art 26 deployer duties and the Art 27 FRIA