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EU AI Act · vendor due diligence

Cohere and the EU AI Act

Foundation models (enterprise NLP)Primarily a GPAI model providerNon-EU headquarters

Toronto-based AI company offering the Command, Embed and Rerank model families, aimed at enterprise text generation, search and retrieval.

What the Act means when you deploy Cohere

Cohere provides general-purpose language models, so the Act's GPAI provider obligations attach to Cohere for those models. Your role is typically deployer (or downstream provider if you build a product on top): classify your own use case, meet transparency duties, and pin down deployment options — Cohere models are also available via clouds and private deployments, which changes who processes your data.

Questions to send Cohere

Copy these into your supplier questionnaire. Answers in writing beat answers on a call — your Article 26 file needs evidence, not recollection.

  1. Q1

    What model documentation and downstream-provider information can you share for the models we use, in line with the AI Act's GPAI provisions?

  2. Q2

    Which deployment options (SaaS, cloud marketplace, private/VPC) are available, and where does our data get processed in each?

  3. Q3

    Is our data used for model training by default, and how do we opt out?

  4. Q4

    What are your data-retention defaults for prompts and outputs, and can we tune them?

Documents to request for your file

  • Instructions for use / product documentation for the exact service and version you deploy
  • Model documentation and information for downstream providers, per model in use
  • Data processing agreement, sub-processor list and processing locations
  • Security documentation: certifications, retention defaults and access controls
  • Written statement on whether your inputs and outputs are used for training, and how to opt out
  • Licence terms for the exact version you deploy, including commercial-use conditions

Which of these you can actually obtain depends on your contract and tier — treat the list as a checklist to work through with the vendor, not as an entitlement.

Articles to have on the table

  • Art. 53
    GPAI provider duties (the vendor's, not yours)

    Cohere is described here as a provider of general-purpose AI models. Technical documentation, information for downstream providers, a copyright policy and a training-content summary are obligations of the model provider — request the resulting artefacts for your own file.

  • Art. 26
    Deployer obligations

    If you use this vendor's technology professionally in a high-risk context, you must follow the instructions for use, assign competent human oversight, keep logs and monitor operation.

  • Art. 25
    When you become the provider

    Putting your own name on the system, changing its intended purpose or substantially modifying it moves you from deployer to provider — with Article 16 obligations attached.

  • Art. 50
    Transparency towards people

    Where people interact with an AI system, or where content is AI-generated or manipulated, disclosure and — in defined cases — machine-readable marking are required. This duty sits with you, not the vendor.

Most buyers of AI land in the deployer role. Read the full deployer obligations under Article 26 — or the overview of all operator roles if you are not sure which one you hold.

Go to the source

Verify everything on this page with Cohere directly. Public pages change; profiles do not update themselves.

Important: what this page is not

This profile is based on publicly available information about Cohere and describes only who they are and what they offer. It makes no assessment of Cohere’s compliance, contains no rating or certification claim, and is not endorsed by or affiliated with Cohere.

EU AI Act obligations depend on how you deploy this vendor's technology and on your role (provider, deployer, importer, distributor). Verify every fact and commitment directly with the vendor before relying on it — this profile is a starting point, not legal advice.

Nothing here is legal advice. Confirm the facts with the vendor and your own counsel before you rely on them.

Which obligations apply to your use of Cohere?

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When do these duties actually start?

We will email you the staged EU AI Act dates, so your review of Cohere is measured against the right clock rather than a vague sense of "2026".

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