Technology providers
Under the AI Act, an AI system provider has different obligations from its customer, and the customer will ask about both
The AI Business Center Foundation (AIBC) is a think tank and advisory partner that helps the boards of construction, industrial and technical-services companies adopt artificial intelligence so that it delivers measurable results and builds competitive advantage. We help AI system providers put their obligations and their answers to customers in order.
Compliance is no longer an annex to the offer. It has become part of the product
Companies that build and sell AI systems for industry and construction are providers under the AI Act. Their customers are deployers. The two roles carry different obligations and different dates, and the customer’s purchasing department increasingly asks about both. A provider with an orderly answer does not have to go through the same conversation in every tender.
How cost and risk arise
- questions from the customer’s legal department, answered by an unprepared sales team,
- the obligation of providers of tools that generate images, video, audio or text to mark content in a machine-readable format (Art. 50(2)), with the transition period ending on 2 December 2026 for tools placed on the market before 2 August 2026,
- uncertainty about whether the product, in a customer’s particular use, could be a high-risk system,
- sales materials that promise “compliance” without stating with what and to what extent,
- a product that language models describe differently from how the provider would wish, at the very moment the customer is drawing up a shortlist.
The same mechanism applies to specifications: designers and contracting authorities increasingly start a technical description from an AI assistant’s draft, and the way the model describes a product’s parameters carries over into the document. A provider that knows what models say about its product can correct errors in the documents that models read. We describe the phenomenon in the analysis Specifications drafted by language models.
The first step
A map: the products, their intended purpose, the company’s role under the AI Act, the obligations and the dates. Alongside it, a list of the questions customers asked in recent procurement procedures, and the answers the company can document. We assess borderline cases with the company’s legal adviser.
What the Foundation does
- AI Act and ESG compliance: the provider role, a map of obligations with dates, documentation for customers, transparency.
- AIBC Certification Path: preparing the organisation for conformity assessment, and an AIBC attestation with a stated scope and date.
- Brand research in language models: how language models describe and recommend the product.
- GenAI competence: supporting the development of AI literacy of staff (Art. 4) in sales and implementation teams.
The full AI Act calendar and a discussion of Art. 50 are on the page AI Act in communication and sales.
Frequently asked questions
Which Art. 50 obligations apply to providers of content-generating tools?
Art. 50(2) requires providers to mark content generated by their systems in a machine-readable format. For providers of tools placed on the market before 2 August 2026, the transition period ends on 2 December 2026; new tools must meet the obligation straight away.
When do the requirements for high-risk systems apply?
Following the amendment introduced by the AI Omnibus, the obligations of providers and deployers of high-risk systems under Annex III apply from 2 December 2027, and for systems under Annex I from 2 August 2028. Whether a particular system is high-risk is assessed on the basis of its intended purpose.
Does the AIBC attestation replace a conformity assessment?
No. The AIBC Certification Path is the Foundation's own standard: preparing the organisation for conformity assessment, and the AIBC attestation. Where the law requires a conformity assessment, it is carried out according to the procedures laid down in the law.
Let’s start with a conversation
Let’s talk about the questions customers are putting to your sales team today.