- Situation
- An AI scheduling product assumed it was a deployer under the EU AI Act because it had trained no models of its own. It was licensing a third-party model and shipping it under its own brand, which on the facts pointed to provider status.
- Why it mattered
- The provider obligation set is an order of magnitude heavier. An investor questionnaire had already asked the question and the company had answered it wrongly, in writing.
- Work
- Territorial scope assessment, role reclassification across four systems, risk tiering, an AI system inventory, redesigned in-product transparency, and rewritten model vendor terms with flow-down obligations.
- Outcome
- A defensible written classification, a corrected position with the investor, and a governance pack that closed the diligence item rather than reopening it.
- Duration
- 14 business days