A side-by-side comparison of Placing on the Market and Putting into Service. Understand how first EU market availability differs from first operational use for an intended purpose.
Placing On The Market defines first making available of an AI system or general-purpose AI model on the EU market.
Context: Most relevant when assessing market-entry obligations before an AI system or GPAI model is made available in the EU.
Putting Into Service defines supplying an AI system for its first use by a deployer or for the provider's own use in the Union.
Context: Most relevant when assessing obligations tied to first operational use of an AI system in the EU.
| Aspect | Placing On The Market | Putting Into Service |
|---|---|---|
| Regulatory purpose | Placing on the market identifies the first making available of an AI system or GPAI model on the EU market. | Putting into service identifies the first use of an AI system for its intended purpose in the Union. |
| Trigger point | Triggered by first EU market availability. | Triggered by first operational use by a deployer or the provider itself. |
| Required evidence | Evidence should support compliance before or at market entry. | Evidence should support readiness for intended operational use. |
| Responsible actor | Most closely linked to the actor making the system or model available on the EU market, often the provider. | Linked to the actor supplying or using the system for first intended use, including provider or deployer contexts. |
| Audit implication | Auditors should check whether pre-market obligations were satisfied before the first market event. | Auditors should check whether operational-use controls were ready before first intended use. |
In practice, product teams should build separate gates for market release and operational activation, because a system can be commercially available before a specific deployer starts using it.
Using market launch and first operational use as interchangeable milestones.
Waiting until first deployment to prepare evidence needed before market placement.
Ignoring provider's own use when assessing putting into service.
Use Placing on the Market when the issue is first EU market availability of an AI system or general-purpose AI model. It is the right term for pre-market checks, provider evidence, and CE-related workflows where applicable.
Use Putting into Service when the issue is first intended operational use in the Union. It is the right term for deployment-readiness, use-context controls, and evidence tied to actual operation.
Under the EU AI Act, these lifecycle triggers help decide when obligations must be satisfied. Treating them as the same can cause teams to prepare evidence too late or assign responsibility to the wrong actor.
No. Placing on the market concerns first EU market availability, while putting into service concerns first intended use in the Union.
Yes. They can occur close in time, but the legal concepts still answer different lifecycle questions.
Separate triggers make it easier to assign owners, prepare evidence, and confirm that obligations are satisfied before the relevant lifecycle event.
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