The EU AI Act sorts accountability into two buckets: providers build AI systems, deployers operate them. Article 3(1) treats every agent as an AI system. Straightforward enough when a human decides what gets deployed.
Agent orchestration scrambles the mapping. When an orchestrator spawns subagents at runtime, each carries an intended purpose defined by another agent, not a person. The Act offers no mechanism for recursive delegation. The EU AI Office itself has flagged the deployer/provider boundary as unresolved guidance work. Enforcement powers activate August 2, 2026.