European UnionAI Act, Article 25 (responsibilities along the AI value chain)
Regulation (EU) 2024/1689, Article 25
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What follows is LexLint's own research summary of this law, not legal advice.
An AI risk obligations rule binding public and private bodies.
As of 23 September 2026.
What it requires
- If you are a distributor, importer, deployer, or other third party who puts your name or trademark on a high-risk AI system already on the market, makes a substantial modification to one that keeps it high-risk, or changes an AI system's intended purpose so it becomes high-risk, you are treated as its provider and take on the Article 16 provider obligations.
- If you are the initial provider and one of those events happens, closely cooperate with the new provider: make available technical documentation sufficient to assess compliance with Article 16, inform them of known limitations and failure modes, and give them targeted technical access, including for testing and validation, unless you clearly specified that your system was not to be changed into a high-risk one.
- If you are a product manufacturer and a high-risk AI system is a safety component placed on the market or put into service under your name or trademark, you are treated as its provider.
- If you are the provider of a high-risk AI system, or a third party supplying an AI system, AI model, tool, service, component, or process it integrates, specify by written agreement the necessary information, capabilities, technical access, and other assistance needed for the provider to comply with this Regulation, unless the third party makes the tool, service, process or component available to the public under a free and open-source licence; that exception never covers a general-purpose AI model.
If you get it wrong
Criminal exposureNo
Private right of actionNo
Penalty structure
Article 99(4), point (da), inserted by Regulation (EU) 2026/1744, fines non-compliance with the obligations of providers and operators under Article 25(2) and (4) up to EUR 15,000,000 or 3% of worldwide annual turnover, whichever is higher. Article 99(6) requires the lower of the two for an SME; Article 99(6a), also inserted by that Regulation, requires the lower of the two for a small mid-cap enterprise, since both apply to paragraph 4 fines.
- Rule
- Lower of for SME
- As of
- 23 September 2026
- Currency
- EUR
- Fixed cap
- 15,000,000
- Turnover percentage cap
- 3
Who enforces it
Enforcement body
National market surveillance authorities, at least one designated by each Member State under Article 70(1).
What it reaches
How the hook was established
express
What makes it apply
Market targeting, Operator establishment, Place of effect
Obligation class
Governance, Contract terms
What it makes you log
Who may demand the log
Counterparty
What the log must hold
System identity
Logging duty
Paragraph 2 requires the initial provider to make available technical documentation sufficient to assess Article 16 compliance and to inform the new provider of known limitations and failure modes. It never uses the words logs, records, or audit trail, but the duty cannot be met without documenting the system's design and known limitations.
- Kind
- Implicit
- As of
- 23 September 2026
- Provision
- Article 25(2)
Who checks it
Audit expectation
none
Also on the record
EEA status
- Status
- Pending
- Source link
- https://www.efta.int/eea-lex/32024r1689
What this law does
Drafted with AI from the cited sources under the direction of UnGovr staff. UnGovr holds editorial responsibility for this page.
Article 25 decides who counts as the provider of a high-risk AI system along its supply chain. A distributor, importer, deployer, or other third party is treated as the provider, and takes on the Article 16 provider obligations, if it puts its own name or trademark on a high-risk system already on the market, makes a substantial modification that keeps it high-risk, or changes an AI system's intended purpose so it becomes high-risk.
As amended by the Digital Omnibus on AI (Regulation (EU) 2026/1744, in force since 27 July 2026), paragraph 2 then requires the initial provider to closely cooperate with the new provider, in particular by making available technical documentation sufficient to assess Article 16 compliance, informing the new provider of known limitations and failure modes, and providing targeted technical access, including for testing and validation, unless the initial provider clearly specified that its system was not to be changed into a high-risk one.
A product manufacturer is treated as the provider where a high-risk AI system is a safety component placed on the market or put into service under the manufacturer's own name or trademark.
Paragraph 4, also amended by the Digital Omnibus to add 'AI model' to the list of what a third party may supply, requires the provider of a high-risk AI system and a third party supplying an AI system, AI model, tool, service, component, or process the system integrates to specify by written agreement the necessary information, technical access, and other assistance, unless the component is supplied under a free and open-source licence by a party other than a general-purpose AI model provider.
The Digital Omnibus inserted Article 99(4), point (da), fining non-compliance with the paragraph 2 and paragraph 4 obligations up to EUR 15,000,000 or 3% of worldwide annual turnover, whichever is higher, with the lower of the two for an SME or a small mid-cap enterprise.
Article 25 sits in Chapter III, Section 3, so like Articles 12, 19, 21 and 26 it takes effect on the schedule the Digital Omnibus wrote into Article 113: 2 December 2027 for a system classified as high-risk under Article 6(2) and Annex III, and 2 August 2028 for one classified under Article 6(1) and Annex I.
When LexLint raises it
high_risk_decisionsdistributes_software_producttrains_models
Read the law
Every line above is drawn from the primary source linked here, read on the date shown. This is a research summary, not legal advice.