Putting into Service
Art. 3(11) EU AI Act — first use by the deployer
TL;DR
Putting into Service is defined in Art. 3(11) EU AI Act: the first use of an AI system by the deployer — NOT test use, but productive use for the intended purpose.
What is putting into service?
Key consequences of putting into service:
- Deployer obligations under Art. 26 EU AI Act apply
- For high-risk systems: the FRIA must be completed BEFORE putting into service (Art. 27)
- AI literacy training for the deployer's staff (Art. 4) is mandatory
Practical example
A law firm tests an AI contract analysis tool internally (sandbox). Putting into service only occurs once the AI is used in the productive workflow for real client matters.
Frequently asked questions
Is a pilot enough?
A pilot with real data + real use cases = putting into service. Sandbox testing without real data: no.
What must be done BEFORE putting into service?
FRIA (for high-risk systems), AI literacy training, review of the provider documentation, extension of the privacy notice.
Who is liable?
The deployer for the putting-into-service obligations, the provider for design and safety defects of the model.
See also
Practitioner note: This article is practice-oriented compliance documentation, not legal advice. We are compliance specialists, not a law firm. For legally binding advice, consult an admitted lawyer.