Map of the AI Act

Article 99, 100 and 101: the penalty structure per obligation

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obligation

Article 99, 100 and 101: the penalty structure per obligation

The Regulation carries no single fine amount. For operators, three ceilings attach to different paragraphs of Article 99; in addition the Commission itself fines providers of general-purpose AI models under Article 101, the AI Office can fine in its own right since the 2026 amendment, and Union institutions and bodies face the separate amounts of Article 100. Which ceiling applies depends on which provision was infringed and on who enforces, and not on how serious the consequences are.

based on

Article 99, 100 and 101 on EUR-Lexguidance

is affected

supervises

calls for

Assign to each obligation the penalty ceiling that belongs to itaction · editorial reading

evidenced by

controlled by

Recording of the factors in Article 99(7)control · editorial reading

supported by

Full text of Article 99, 100 and 101template · editorial reading

Legendroleobligationactionevidencesolid line: official findingdashed line: our reading

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obligation

Article 99, 100 and 101: the penalty structure per obligation

The legal path

Source ·: Article 99, 100 and 101 on EUR-Lex
Condition ·: Relevant as soon as you are an operator within the meaning of the Regulation, that is a provider, product manufacturer, deployer, authorised representative, importer or distributor, and one of the provisions named in Article 99(3), (4) or (5) is engaged. The Article 101 regime is additionally relevant where you are a provider of a general-purpose AI model, because there the Commission fines you itself. If you fall within the competence of the AI Office under Article 75(1), Article 75c is added on top.
Exception ·: Paragraph 6 reverses the calculation for SMEs, including start-ups: for them the lower of the percentage and the amount applies, where for other undertakings it is the higher of the two, and it does so for every fine referred to in Article 99. The inserted paragraph 6a does the same for small mid-cap enterprises, but expressly only for paragraphs 4 and 5, so the Article 5 band is not reversed for them. Paragraph 8 leaves it to each Member State to determine to what extent administrative fines may be imposed on public authorities and bodies established in that Member State, so the ceiling for a public organisation does not follow from the Regulation. Paragraph 9 allows the fine to be imposed by the competent national courts or by other bodies rather than by the authority in some Member States.

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Checked on 2026-08-08T00:00:00.000Z · praxikon:eu:ai-act:obligation:article-99-101-penalties

Read the map atin force now 2 Feb 2025 2 Aug 2025 27 Jul 2026 2 Aug 2026 2 Dec 2026 2 Aug 2027 2 Dec 2027 2 Aug 2028

Read at 2 Aug 2027. What did not yet apply on that date is not shown here. GPAI models already on the market before 2 August 2025 must comply.