Your role is decided per system, not per company

A mid-sized company is usually a deployer of many vendor tools and a provider of the one or two AI features it ships. Running the triage once at company level produces the wrong answer for both.

The most common way this goes wrong is a workshop where someone asks "are we a provider or a deployer?" and the room produces one answer. There is no single answer to give. A company that ships an AI feature and uses a vendor's support triage tool is both, at the same time, on different systems.

Run it per system

Each system gets its own row: what it does, who built it, whether it was modified, whose name is on it, and what the intended purpose is. The role falls out of those facts. Two systems with identical technology can land in different roles because one carries your trademark and the other does not.

Re-run it when the facts change

The classification is not settled once. It moves when the model underneath is swapped, when a fine-tune lands, when the intended purpose widens, when an Annex III entry is amended, or when a phasing date arrives. A triage record that is never revisited is a snapshot of a system that no longer exists.

What to keep

Keep the inputs alongside the conclusion. A classification without its facts cannot be reviewed, and an unreviewable classification is the thing that fails first when someone challenges it — internally or from outside.

This is decision-support drafting. Qualified counsel determines the role; the tool exists so the facts they need are already in one place.

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