CLAIM-2026-07-30-05

Article 99(4) sets administrative fines for non-compliance with Article 50 at up to EUR 15 000 000 or, for an undertaking, up to 3 % of total worldwide annual turnover for the preceding financial year. Article 99(6) provides that for SMEs, including start-ups, the fine is capped at the lower of the percentage or the amount.

Why it matters

The SME inversion in paragraph 6 is almost never quoted and it materially changes the exposure calculation for a small Berlin shop: the cap is the lower of the two figures, not the higher.

Sources

• euartificia2026article
• stibbe2026transpare