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A ceiling is not an automatic fine. Identify the applicable provision and specific circumstances.
General information checked on 17 October 2026. Obtain qualified advice on the specific case; this article is not legal advice.
There is no single fine for all AI use.
Article 99 distinguishes infringement categories. The table shows three general undertaking ceilings, not every penalty regime. General-purpose model providers have specific provisions.
Company size matters.
For SMEs including startups, Article 99 uses the lower amount or percentage for paragraphs 3–5. Small mid-caps have a specific rule for paragraphs 4–5. Authorities consider circumstances including severity and duration; this table does not calculate a company’s penalty.
The dates have changed.
The Commission states the AI Omnibus entered into force on 27 July 2026. Annex III high-risk rules apply from 2 December 2027, and product-embedded high-risk rules from 2 August 2028. Other provisions, including specific transparency requirements, follow different dates. Deferrals are not a general suspension.
Prepare a system inventory.
Record system, intended use, business role, affected people and source date. Have the legal classification assessed by a qualified professional, then design technical controls and handoffs around agreed requirements.
ARXE Studio develops custom integrations. An “AI compliant” label is not a promise of legal certainty. The mini-check illustrates how to read a claim; it estimates no fines.
| Article 99 infringement | General undertaking ceiling | Paragraph |
|---|---|---|
| Prohibited practices | EUR 35 m or 7% of preceding worldwide annual turnover, whichever is higher | 3 |
| Listed duties, including Article 50 | EUR 15 m or 3%, whichever is higher | 4 |
| Requested incorrect/incomplete/misleading information | EUR 7.5 m or 1%, whichever is higher | 5 |
Make the call.
A headline states a maximum fine. What do you check next?
Choose an answer to see the reasoning.
Local, deterministic example. No data sent and no AI model called.
Sources and further reading
How this content is made
Text prepared with AI assistance. Original examples and mini-checks are simulated and show no clients or measured results. The fictional characters are not the authors.
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