An AI user is any individual, company, or public authority that uses an AI system within the European Union. Under the EU AI Act, users play a distinct role in the AI ecosystem, with specific obligations depending on the risk classification of the system—particularly if it is high-risk. Users must ensure lawful use, monitor performance, and, in some cases, contribute to ongoing risk management and post-market oversight.
1. Background and Establishment
The EU Artificial Intelligence Act introduces a role-specific approach to regulation, assigning obligations based on where an actor sits in the AI value chain. While AI providers are responsible for development and market placement, AI users—also called “deployers”—are responsible for how these systems are used in practice.
Whether in healthcare, hiring, education, finance, or law enforcement, users of AI systems are required to ensure appropriate, informed, and compliant application of these technologies.
2. Purpose and Role in the EU AI Ecosystem
AI users serve as the final interface between AI systems and real-world impacts. Their responsibilities are designed to:
- Prevent unlawful or unintended uses of AI
- Ensure human oversight and control
- Facilitate the detection of system errors or malfunctions
- Protect end-user rights, particularly when outcomes significantly affect individuals
- Contribute to post-market monitoring and transparency
The AI user’s conduct determines whether even a legally compliant system is ethically and practically acceptable in deployment.
3. Key Contributions and Impact
Properly informed AI users help to:
- Detect and report anomalies or malfunctions
- Maintain system safety and transparency throughout its operational context
- Ensure AI use aligns with data protection laws, especially GDPR
- Prevent misuse in high-risk environments such as employment or public security
- Reinforce trust and legitimacy in AI-based services
Negligent or unauthorized use of AI systems—even if technically compliant—can lead to regulatory action, reputational damage, or legal liability.
4. Connection to the EU AI Act and the EU AI Safety Alliance
AI user obligations are detailed in:
- Article 3(4) – Defines the “user” as any natural or legal person using an AI system under their authority
- Articles 29–31 – Outline user-specific obligations for high-risk AI systems
- Article 62 – Users must report serious incidents and malfunctions to providers or regulators
- Annex III – Identifies high-risk use cases (e.g. biometric identification, recruitment, education) where user diligence is critical
The EU AI Safety Alliance supports users by providing:
- User-specific training modules
- Usage protocols for high-risk systems
- Incident reporting tools
- Guidance on compliance collaboration with providers
This infrastructure ensures that users fulfill their legal role in preserving safety, legality, and accountability in AI use.
5. Stakeholder Responsibilities and Legal Boundaries
AI users must:
- Operate the AI system within the boundaries defined by the provider
- Follow user instructions, including on system limitations and oversight needs
- Monitor system outputs for unintended consequences or biases
- Maintain records of system performance (where applicable)
- Ensure human review of automated decisions where legally required
- Report anomalies or serious incidents promptly to the provider or authority
For high-risk systems, users may be subject to audits and regulatory scrutiny.
6. Common User Scenarios and Risk Levels
Examples of AI users include:
- HR departments using AI for candidate ranking (high-risk)
- Police agencies deploying facial recognition tools (high-risk or prohibited)
- Teachers using adaptive learning platforms (potentially high-risk)
- Banks using credit scoring algorithms (high-risk)
- Retailers using recommendation systems (low-risk or minimal-risk)
Obligations vary: high-risk users face more rigorous duties, while general-purpose or low-risk system users are primarily responsible for ethical usage and transparency.
7. How to Operate as a Compliant AI User Under the EU AI Act
To align with the EU AI Act:
- Identify the AI system’s risk classification before use
- Request and review the system’s conformity documentation from the provider
- Follow provider-issued user instructions precisely
- Establish human oversight procedures for automated outputs
- Train internal teams on risk awareness and operational limits
- Report serious incidents via established communication pathways
- Use the EU AI Safety Alliance as a resource hub for operational guidance
Where doubts exist, users must err on the side of precaution and documentation.