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Policy & LawAlmost nobody caught this

The EU sets out how it will fine ChatGPT and Gemini under the AI Act

The European Union has published the rules it will use to fine providers of general-purpose AI models, such as ChatGPT and Gemini, under the AI Act. Almost nobody covered it, but this is the part of the law that turns obligations into money.

The AI Act already sets the ceilings. Providers of general-purpose models can face fines of up to 3% of global annual turnover or 15 million euros, whichever is higher, for breaking their obligations, which include technical documentation, transparency about training data, copyright policies and, for the most capable models, risk assessment and incident reporting. What has been missing is the procedure: how the European Commission investigates, how it weighs a breach and how a fine is set.

That procedure is what this publication fills in. For the big model providers it means the cost of non-compliance can now be estimated rather than guessed. For companies that build on those models, it means the providers will push compliance requirements and paperwork down the supply chain.

Our take

Rules without fines are guidance. Published fine mechanics are what turn the AI Act into a budget line for legal teams.

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