EU AI Act Position Statement
Our role under Regulation (EU) 2024/1689 (the EU AI Act), and how we help clients meet their obligations.
1. Our role
OFORO LTD is not a provider of an AI system within the meaning of Article 3(3) of Regulation (EU) 2024/1689. We provide evaluation services (Nxted Expert) and training data licensing (Nxted Capture). Clients remain the providers of their own AI systems and retain the regulatory responsibilities that come with that role.
2. How we support client compliance
- Article 10 - Data and data governance. Capture footage is delivered with documented data provenance, consent records, balanced demographic sampling where the client specifies it, and quality controls (review of every batch before delivery).
- Annex IV - Technical documentation. Our quality reports include evaluation methodology, expert credentials (degree, institution, years of experience), inter-rater agreement metrics, and error taxonomy - designed to drop into Annex IV documentation packs.
- Article 14 - Human oversight. Our evaluation interface preserves the role of human experts as the source of ground truth; we do not substitute fully automated scoring.
- Article 15 - Accuracy, robustness, cybersecurity. Our red-team engagements directly test these properties.
- Articles 53, 55 - General-purpose AI models. For clients training GPAI models (including those crossing the systemic-risk threshold), our evaluations and capture data can feed the transparency, technical documentation, and post-market monitoring obligations effective 2 August 2025.
3. Prohibited practices (Article 5)
We will not provide services that support practices prohibited under Article 5 - see the Acceptable Use Policy for the full list.
4. Authorised representative
Where Article 22 requires a Client to appoint an authorised representative in the Union, we do not act as that representative. We can introduce Clients to specialist firms providing this service.
5. Updates
We will update this statement as the European Commission publishes implementing acts, harmonised standards (CEN-CENELEC JTC 21), and the AI Office issues guidance. This page is informational and is not legal advice; engage qualified counsel for your specific compliance posture.
OFORO LTD · Registered in England & Wales · Company No. 16787568 · Unit 8 Lyon Road, Milton Keynes, England, MK1 1EX
Questions: legal@nxted.ai · DPO: dpo@nxted.ai