Fine-tune and you may become the provider: the Article 25 role-shift

A recurring misconception is that buying an AI system from a vendor keeps the buyer in the lighter deployer role. Article 25 says otherwise in three situations.

A deployer, distributor or importer is treated as a provider — and inherits provider obligations — if it puts its own name or trademark on a high-risk system, makes a substantial modification to one, or changes a system's intended purpose so that it becomes high-risk.

For organisations fine-tuning or repurposing foundation models this is the clause to watch. A modification made for a legitimate product reason can quietly transfer the technical documentation, conformity and registration burden from the original vendor onto you, on the same system you thought you were merely deploying.