Official-source-backed technical resource
Prepare a vendor role fact questionnaire
Ask how the system is developed, branded, placed into service and used before assigning provider or deployer roles. Includes a free implementation worksheet.
Short answer
Ask how the system is developed, branded, placed into service and used before assigning provider or deployer roles. Collect facts that a qualified reviewer can assess.
Download the blank working record (.md)
When to use this guide
A contract calls every party a deployer even though one party commissions and markets the system under its own brand.
This is a fictional implementation scenario. The procedure below is Article 50 Hub's suggested working method, not a prescribed legal form, a customer result or a claim that every step is an additional statutory requirement.
Review procedure
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Identify the entities and the actual development and branding arrangements.
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Ask who places the system into service and who controls its use.
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Record changes, integrations and customer-facing presentation that may affect the assessment.
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Submit unresolved facts and contract wording to the responsible reviewer.
What the example review finds
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The contract label conflicts with the described branding arrangement.
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No one has documented who controls the deployed system.
Keep these example observations separate from your own results. An unknown or untested state should stay open until the relevant evidence has been inspected.
Fields for your working record
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Entity
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Development role
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Branding
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Operational control
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Open question
Use the downloadable blank worksheet linked on this page to connect the observed behavior with the deployed system. Add a reviewer, date, evidence reference, unresolved questions and a next action. The worksheet is editable locally and does not upload your records to Article 50 Hub.
Completion and handoff
Close the task only for the scope actually reviewed. Preserve the result that another authorized reviewer can reproduce, identify the owner of remaining work, and record a retest when the implementation changes. A completed worksheet is not a substitute for the underlying evidence.
Decision boundary
Contract terminology alone does not determine statutory roles or transfer obligations.
The official references below provide legal or technical context. Resolve applicability and exception questions with the responsible qualified reviewer; use the product's tools to organize implementation work within that assessment.
Official sources
- EU AI Act — legal text and contextEUR-Lex
- Commission FAQ — transparency obligations and scopeEuropean Commission
- Article 50 Service Desk — read with its amendment notice and current Commission guidanceEuropean Commission
Last reviewed: 2026-09-23. This is technical implementation information, not legal advice.