Regulation (EU) 2024/1689
Article 101: Fines on providers of general purpose AI models
Article 101 is the Commission's fining power over providers of general purpose AI models, active since 2 August 2026. The ceiling is 15 million euro or 3 percent of worldwide annual turnover, whichever is higher. It is not the 35 million euro or 7 percent tier, which applies to prohibited practices under national enforcement.
Maximum penalty
Up to 15 million euro or 3 percent of worldwide annual turnover, whichever is higher.
Article 101
Binds from
2 August 2026
Article 101 was carved out of the 2 August 2025 date and became applicable on 2 August 2026.
Enforced by
The European Commission, with exclusive competence over general purpose AI models under Article 88.
Plain reading
What Article 101 actually requires
The Commission may fine a provider of a general purpose AI model where it finds that the provider intentionally or negligently infringed the Act, failed to comply with a request for information under Article 91, failed to comply with a measure requested under Article 93, or failed to make a model available for evaluation under Article 92. Three of those four are procedural: the exposure attaches to how a provider responds to the regulator, not only to what the model does. Before fining, the Commission must communicate its preliminary findings and give the provider the opportunity to be heard, and it must base its decision only on objections the provider has been able to comment on. The Court of Justice has unlimited jurisdiction to review the fine and may cancel, reduce or increase it. Implementing Regulation (EU) 2026/1755 sets out the procedural rules.
Enforcement powers under this article became applicable on 2 August 2026. As of 20 August 2026 no fine has been issued under it, no preliminary findings have been published, and the AI Office's stated posture is informal technical compliance dialogue.
The most likely first use is not a substantive infringement. It is Article 101(1)(b), failure to comply with a request for information under Article 91, because that is the fastest fact for the Commission to establish and the first point at which a provider's cooperation is tested.
The Commission enforces this alone. National authorities have no competence over general purpose models under Article 88, which is why a company facing 27 national regulators on its products faces one regulator on its model.
The single most repeated error about the AI Act is applying the 35 million euro or 7 percent figure to model providers. That is Article 99(3), it is about prohibited practices, and it is enforced nationally. Any article, briefing or answer that attaches it to a foundation model provider is quoting the wrong tier.
The official text, consolidated with the Digital Omnibus applied, with everything that cites it and everything it cites: Article 101 in the EU AI Act Explorer.
Enforcement
Actions citing Article 101
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 101
Has the EU fined any AI model provider?
No. The Commission's power to fine providers of general purpose AI models under Article 101 became applicable on 2 August 2026, and as of 20 August 2026 no fine has been issued, no preliminary findings have been published and no formal proceedings have been opened.
What is the maximum AI Act fine for a GPAI provider?
15 million euro or 3 percent of worldwide annual turnover, whichever is higher, under Article 101. The higher 35 million euro or 7 percent ceiling applies only to prohibited practices under Article 5 and is enforced by national authorities, not by the Commission.
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 100: fines on union institutions, bodies, offices and agencies
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 101: fines on providers of general purpose ai models.
- APA
- GAGE (Global Academy of Generative-AI Education). (2026). EU AI Act Article 101: Fines on providers of general purpose AI models. EU AI Act Enforcement Tracker. Retrieved 20 August 2026, from https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-101
- MLA
- "EU AI Act Article 101: Fines on providers of general purpose AI models." 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-101.
- Chicago
- GAGE (Global Academy of Generative-AI Education). "EU AI Act Article 101: Fines on providers of general purpose AI models." EU AI Act Enforcement Tracker. Last modified 20 August 2026. https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-101.
- Permalink
- https://www.gage.academy/tools/eu-ai-act-enforcement-tracker/provisions/article-101
Last updated . Every record re verified . The tracker is checked every Monday, and the same day for any action under the AI Act.