🤖 AI Summary
This paper addresses the challenge of clarifying and coordinating responsibilities among six key actor roles—providers, deployers, authorized representatives, importers, distributors, users, and notified bodies—under the EU Artificial Intelligence Act (Regulation (EU) 2024/1689). Applying systematic legal text analysis, the study examines all 113 articles, 180 recitals, and 13 annexes. It proposes a dynamic role-transformation mechanism grounded in the principle that “control determines responsibility,” revealing how obligations cascade along the AI supply chain. The paper’s primary contribution is an original AI regulatory actor mapping framework that operationalizes the “responsibility follows control” principle to enable distributed, cooperative governance. This framework balances fundamental rights protection with innovation support by clarifying role-specific duties and interdependencies. It delivers actionable guidance for regulators, AI providers, deployers, and other compliance stakeholders on role identification and obligation fulfillment under the AI Act.
📝 Abstract
The European Union's Artificial Intelligence Act (Regulation (EU) 2024/1689) establishes the world's first comprehensive regulatory framework for AI systems through a sophisticated ecosystem of interconnected subjects defined in Article 3. This paper provides a structured examination of the six main categories of actors - providers, deployers, authorized representatives, importers, distributors, and product manufacturers - collectively referred to as "operators" within the regulation. Through examination of these Article 3 definitions and their elaboration across the regulation's 113 articles, 180 recitals, and 13 annexes, we map the complete governance structure and analyze how the AI Act regulates these subjects. Our analysis reveals critical transformation mechanisms whereby subjects can assume different roles under specific conditions, particularly through Article 25 provisions ensuring accountability follows control. We identify how obligations cascade through the supply chain via mandatory information flows and cooperation requirements, creating a distributed yet coordinated governance system. The findings demonstrate how the regulation balances innovation with the protection of fundamental rights through risk-based obligations that scale with the capabilities and deployment contexts of AI systems, providing essential guidance for stakeholders implementing the AI Act's requirements.