# The EU AI Act makes whoever puts their own name or trademark on a high-risk AI system its provider, with the full provider obligations (Article 25), applying from December 2027

Page: https://flyvolo.ai/en/changes/ev-20260802-partnerships-manager-1
Date: 2024-08-01 · Stage: Constraint
Can this record move a task judgement? yes
Occupation: https://flyvolo.ai/en/careers/partnerships-manager

## Scope

The EU market, and only for systems that are high-risk under Article 6. Article 25(1)(a) attaches a legal consequence to one specific act — putting your own name or trademark on a high-risk system already placed on the market — and Article 25(2) then strips the original provider of that status, so the liability moves rather than being shared. Article 25(4) separately requires the provider and a third party supplying tools, services or components to fix the necessary information and technical access in a written agreement; that is context for what such a contract must cover, not evidence about who negotiates it. Regulation (EU) 2026/1744 (the Digital Omnibus on AI, published 24 July 2026) moved the application of these obligations from 2 August 2026 to 2 December 2027 for systems that are high-risk under Annex III, and to 2 August 2028 for those that are high-risk under Article 6(1) and Annex I; so this is a rule on the books that does not yet apply. The text says nothing about how many channel or white-label arrangements exist or whether any has been restructured.

## Source

- Regulation (EU) 2024/1689 (Artificial Intelligence Act), Article 25 and Article 113, as amended by Regulation (EU) 2026/1744 — EUR-Lex consolidated text of 27 July 2026 — https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02024R1689-20260727 (primary source)

## What this means

A constraint on governing what a partner says in your name: once it applies, putting your own name or trademark on a high-risk AI system that someone else placed on the market makes you its provider under EU law, with the full provider obligations, and removes that status from the company that built it. The EU has set that date at December 2027 for most high-risk systems.

## What it does not show yet

The article allocates legal responsibility, and does not yet apply. It does not say how many channel or white-label arrangements exist, whether any partner programme has been restructured because of it, or that a machine is doing any part of this task.

## How to verify it yourself

Open EUR-Lex's consolidated text of Regulation (EU) 2024/1689 (version of 27 July 2026) and find Article 25(1)(a), "they put their name or trademark on a high-risk AI system", then Article 113, point (c).


More: https://flyvolo.ai/llms.txt