Downstream provider

An entity that takes a GPAI model or other third-party AI component and integrates it into an AI system placed on the market or put into service under the entity's own name. If the resulting system is high-risk, the downstream provider becomes a high-risk AI system provider under Article 25 and bears the Article 16 obligations.

An organization that integrates another provider's model into its own AI system. Under the EU AI Act, the model's provider owes the downstream provider documentation (Annex XII) sufficient to understand the model's capabilities and limitations and to meet the downstream provider's own obligations.

A provider of an AI system or GPAI system that integrates a GPAI model; defined in Article 3(68). The downstream provider owes AI system obligations for their system; they are not the Chapter V GPAI model provider unless they place a GPAI model on the market themselves.

A provider of an AI system who integrates a GPAI model into their own AI system. They are entitled to receive the Annex XII information under Article 53(1)(b) and rely on it to comply with their own obligations under the Act.

An entity that integrates a GPAI model into its own AI system. When the upstream GPAI provider is exempt under Article 53(2), the downstream provider cannot rely on formal Annex XII documentation and must conduct due diligence from publicly available parameters.