Article 101: GPAI Fines
Article 101 lets the Commission fine GPAI providers up to 3% of worldwide annual turnover in the preceding financial year, or EUR 15 million, whichever is higher, for intentional or negligent infringement of the Regulation, for failing to respond or giving false or misleading information under Article 91, for non-compliance with a corrective measure under Article 93, or for refusing model access for evaluation under Article 92.
- 02 Aug 2025 In force since — underlying Art. 51-56 obligations apply
- 02 Aug 2026 Full enforcement powers apply (Art. 91-94, 101), confirmed unaffected by the Digital Omnibus
- Respond accurately and completely to Commission document and information requests under Article 91.
- Comply with corrective measures ordered by the Commission under Article 93.
- Provide model access for evaluation under Article 92 when requested.
- Factor fine exposure — up to 3% of worldwide annual turnover or EUR 15 million, whichever is higher — into GPAI compliance risk management.
GPAI providers are sometimes told the general Article 99 fine ceilings apply to them; GPAI-specific violations are fined under the separate Article 101 mechanism, with its own 3%/EUR 15 million ceiling and its own trigger conditions.
What regulators published on Art. 101
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- Regulation (EU) 2024/1689 on EUR-Lex
- Look for Article 101
- Deadline changes and the acts behind them
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Get free accessInformational content only. Not legal advice and not a substitute for qualified counsel. Dates reflect Regulation (EU) 2026/1744 as of 04 Aug 2026.