Regulation (EU) 2024/1689
Article 100: Fines on Union institutions, bodies, offices and agencies
Article 100 gives the European Data Protection Supervisor the power to fine the European Union's own institutions when they breach the AI Act. The ceiling is 1.5 million euro for a prohibited practice under Article 5 and 750,000 euro for other non compliance, and the same rules apply to the Union as to everyone else.
Maximum penalty
Up to 1.5 million euro for an Article 5 prohibited practice, up to 750,000 euro for other non compliance.
Article 100
Binds from
2 August 2025
Applicable with the rest of Chapter XII from 2 August 2025.
Enforced by
The European Data Protection Supervisor.
Plain reading
What Article 100 actually requires
The Union subjected itself to its own regulation, and named a supervisor to enforce it. The EDPS may impose administrative fines on Union institutions, bodies, offices and agencies falling within the scope of the Act, taking into account the nature, gravity and duration of the infringement, whether the same body has been fined before, and the degree of cooperation. The amounts are far lower than the private sector tiers because they come out of a public budget, but the mechanism is real and the EDPS has an established record of formal action against Union bodies under the data protection regulation that applies to them. Funds collected go to the general budget of the Union. Any decision is subject to review by the Court of Justice, which has unlimited jurisdiction to annul, reduce or increase the fine.
The EDPS is designated as market surveillance authority for Union institutions by Article 70(9), so supervision and penalty sit with the same body.
No fine has been imposed under Article 100 as of the last verification date.
This provision matters for a practical reason beyond symbolism. Union agencies procure AI systems, and a supplier that sells into a Union institution is selling into a buyer with its own supervisor, its own compliance exposure and its own reporting duties.
The official text, consolidated with the Digital Omnibus applied, with everything that cites it and everything it cites: Article 100 in the EU AI Act Explorer.
Enforcement
Actions citing Article 100
No tracked enforcement action expressly cites this article. The list below is the conduct that falls inside it, enforced so far under the GDPR or the Digital Services Act instead.
Answers
Questions about Article 100
Does the EU AI Act apply to the EU institutions themselves?
Yes. Union institutions, bodies, offices and agencies are within scope, the European Data Protection Supervisor is their market surveillance authority under Article 70(9), and Article 100 allows it to fine them up to 1.5 million euro for a prohibited practice and 750,000 euro for other non compliance.
The rest of the Act
Other enforceable provisions
- Article 5: prohibited ai practices
- Article 50: transparency obligations for certain ai systems
- Article 51: classification of general purpose ai models with systemic risk
- Article 53: obligations for providers of general purpose ai models
- Article 55: obligations for providers of general purpose ai models with systemic risk
- Article 93: measures the ai office can require of model providers
- Article 99: penalties imposed by member states
- Article 101: fines on providers of general purpose ai models
Cite this page
Free to reuse under CC BY 4.0, with attribution.
- In a sentence
- According to the GAGE EU AI Act Enforcement Tracker (as of 20 August 2026), eu ai act article 100: fines on union institutions, bodies, offices and agencies.
- APA
- GAGE (Global Academy of Generative-AI Education). (2026). EU AI Act Article 100: Fines on Union institutions, bodies, offices and agencies. EU AI Act Enforcement Tracker. Retrieved 20 August 2026, from https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-100
- MLA
- "EU AI Act Article 100: Fines on Union institutions, bodies, offices and agencies." 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/provisions/article-100.
- Chicago
- GAGE (Global Academy of Generative-AI Education). "EU AI Act Article 100: Fines on Union institutions, bodies, offices and agencies." EU AI Act Enforcement Tracker. Last modified 20 August 2026. https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-100.
- Permalink
- https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-100
Last updated . Every record re verified . The tracker is checked every Monday, and the same day for any action under the AI Act.