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Irish DPC opens a cross border inquiry into Google over the PaLM 2 model

Irish DPC took investigation action against Google Ireland Limited over Pathways Language Model 2 (PaLM 2), announced 12 September 2024. No financial penalty was imposed. Status: confirmed.

The record

Key facts

Record ID
AIT-2024-0004
Status
Confirmed
Action type
Investigation
Regime
GDPR
Authority
Data Protection Commission
Jurisdiction
Ireland
Target
Google Ireland Limited, headquartered in Ireland
Sector
Generative AI
AI system
Pathways Language Model 2 (PaLM 2)
Date announced
Amount
No financial penalty
Appeal
None recorded. Not applicable while the inquiry is open.
Last verified

In full

What happened, and why it matters

Ireland's Data Protection Commission opened a statutory inquiry into whether Google carried out a data protection impact assessment before processing the personal data of people in Europe to develop PaLM 2. The question is narrow and it is deliberately narrow. Rather than litigate whether training a foundation model on scraped web data has a legal basis, the DPC asked whether the controller did the assessment that Article 35 requires before high risk processing begins. That is a documentary question with a documentary answer, and it is the same shape as the obligations the AI Act now places on general purpose model providers: Article 53 requires technical documentation, a training data summary and a copyright policy, and the AI Office can demand them under Article 91. The inquiry has not concluded. It is on this tracker because it is the lead regulator of most large model providers in Europe testing the process obligation rather than the substance, and because whatever the DPC concludes about pre deployment assessment will shape how the AI Office reads Article 53 documentation duties on the same models. As of the last verification date no decision or fine has been published.

At a glance

The four things to take away

  • Statutory inquiry announced 12 September 2024 under section 110 of the Irish Data Protection Act 2018.
  • Scope: whether a data protection impact assessment was carried out before processing for PaLM 2.
  • Cross border inquiry, so any draft decision goes through the Article 60 cooperation procedure.
  • No decision, finding or fine published as of 20 August 2026.

The law

Provisions this action rests on

Read the official text of Article 53 in the EU AI Act Explorer, consolidated with the Digital Omnibus applied.

How it moved

Timeline

  1. DPC announces the commencement of the inquiry

Verification

Sources

Primary sources are the authority's own decision or press release, the Official Journal, or a court judgment. A record with no source is not published.

  1. Data Protection Commission, statement on the commencement of an inquiry into Google Ireland LimitedPrimary · 12 September 2024

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Cite this record

Free to reuse under CC BY 4.0, with attribution. The record ID AIT-2024-0004 is permanent and is never reused.

In a sentence
According to the GAGE EU AI Act Enforcement Tracker (as of 20 August 2026), irish dpc opens a cross border inquiry into google over the palm 2 model.
APA
GAGE (Global Academy of Generative-AI Education). (2026). Irish DPC opens a cross border inquiry into Google over the PaLM 2 model. EU AI Act Enforcement Tracker. Retrieved 20 August 2026, from https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2024-0004-irish-dpc-google-palm-2-inquiry
MLA
"Irish DPC opens a cross border inquiry into Google over the PaLM 2 model." EU AI Act Enforcement Tracker, GAGE (Global Academy of Generative-AI Education), 20 August 2026, https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2024-0004-irish-dpc-google-palm-2-inquiry.
Chicago
GAGE (Global Academy of Generative-AI Education). "Irish DPC opens a cross border inquiry into Google over the PaLM 2 model." EU AI Act Enforcement Tracker. Last modified 20 August 2026. https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2024-0004-irish-dpc-google-palm-2-inquiry.
Permalink
https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/actions/AIT-2024-0004-irish-dpc-google-palm-2-inquiry

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