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Regulation Tracker / EU AI Act / Chapter XII

Article 101
Fines for providers of general-purpose AI models

Chapter XII — Penalties. 6 distinct duties, powers or definitions are coded from this article, applying from 2026-08-02.

Amended by Regulation (EU) 2026/1744 (Digital Omnibus on AI), in force 2026-07-27 — about 61 words changed. The text below is the consolidated version of 27 July 2026; the 2024 text and the amending regulation are on EUR-Lex.

official text: EUR-Lex (consolidated 27 Jul 2026) · text © European Union (Decision 2011/833/EU) · coding CC BY 4.0 · data: obligations.json · Hugging Face · GitHub

The text

1. The Commission may impose on providers of general-purpose AI models fines not exceeding 3 % of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000 , whichever is higher., when the Commission finds that the provider intentionally or negligently:

  1. (a)infringed the relevant provisions of this Regulation;
  2. (b)failed to comply with a request for a document or for information pursuant to Article 91, or supplied incorrect, incomplete or misleading information;
  3. (c)failed to comply with a measure requested under Article 93;
  4. (d)failed to make available to the Commission access to the general-purpose AI model or general-purpose AI model with systemic risk with a view to conducting an evaluation pursuant to Article 92.

2. Before adopting the decision pursuant to paragraph 1, the Commission shall communicate its preliminary findings to the provider of the general-purpose AI model and give it an opportunity to be heard.

3. Fines imposed in accordance with this Article shall be effective, proportionate and dissuasive.

4. Information on fines imposed under this Article shall also be communicated to the Board as appropriate.

5. The Court of Justice of the European Union shall have unlimited jurisdiction to review decisions of the Commission fixing a fine under this Article. It may cancel, reduce or increase the fine imposed.

6. The Commission shall adopt implementing acts containing detailed arrangements and procedural safeguards for proceedings in view of the possible adoption of decisions pursuant to paragraph 1 of this Article. Those implementing acts shall be adopted in accordance with the examination procedure referred to in Article 98(2).

What it requires, coded

SafeLegalAI's reading of each duty in this article: who, what, from when, under which fine tier, and whether it reaches a firm, chambers, court or legal-AI vendor. Descriptive, not advice; the quoted words are the Regulation's.

  1. Art. 101(1)PenaltyGeneral-purpose AI

    The Commission may fine GPAI model providers up to 3% of annual total worldwide turnover or EUR 15,000,000, whichever is higher, for intentional or negligent listed infringements.

    "fines not exceeding 3 % of their annual total worldwide turnover in the preceding financial year or EUR 15 000 000 , whichever is higher."
    Who
    Commission, GPAI model provider, GPAI provider (systemic risk)
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Fine tier
    Art. 101
    Legal practice
    Reaches legal-AI vendors or public bodies — Legal-AI vendors that also provide GPAI models may be exposed to this Commission fine tier.
    See
    Art. 91 · Art. 92 · Art. 93

  2. Art. 101(1)PenaltyGeneral-purpose AI

    Fine triggers include infringing relevant AI Act provisions, failing to comply with Article 91 document or information requests, failing Article 93 measures, or failing to provide model access for Article 92 evaluation.

    "when the Commission finds that the provider intentionally or negligently:"
    Who
    GPAI model provider, GPAI provider (systemic risk)
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Fine tier
    Art. 101(1)
    Legal practice
    Reaches legal-AI vendors or public bodies — This identifies the conduct by GPAI providers that can trigger fines, including model-access and information failures.
    See
    Art. 91 · Art. 92 · Art. 93

  3. Art. 101(2)Right of personGeneral-purpose AI

    Before adopting an Article 101 fine decision, the Commission must communicate preliminary findings to the GPAI model provider and give it an opportunity to be heard.

    "the Commission shall communicate its preliminary findings to the provider of the general-purpose AI model and give it an opportunity to be heard."
    Who
    Commission, GPAI model provider
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Legal practice
    Reaches legal-AI vendors or public bodies — GPAI providers connected to legal-AI services receive hearing rights before Commission fines.
    See
    Art. 101(1)

  4. Art. 101(3)PenaltyGeneral-purpose AI

    Fines imposed under Article 101 must be effective, proportionate and dissuasive.

    "Fines imposed in accordance with this Article shall be effective, proportionate and dissuasive."
    Who
    Commission
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Fine tier
    Art. 101(3)
    Legal practice
    Reaches legal-AI vendors or public bodies — This governs Commission fine calibration for GPAI providers, including legal-AI model providers.
    See
    Art. 101

  5. Art. 101(4)Cooperation with authoritiesGeneral-purpose AI

    Information on Article 101 fines must also be communicated to the AI Board as appropriate.

    "Information on fines imposed under this Article shall also be communicated to the Board as appropriate."
    Who
    Commission, AI Board
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Legal practice
    Institutional — This is governance reporting about GPAI fines and has indirect legal-practice relevance.
    See
    ai-board

  6. Art. 101(5)Right of personGeneral-purpose AI

    The Court of Justice may review Commission fine decisions with unlimited jurisdiction, and the Commission must adopt implementing acts on detailed arrangements and procedural safeguards.

    "It may cancel, reduce or increase the fine imposed."
    Who
    Commission, Other
    From
    (Art. 113 second subparagraph (Art. 101 excepted from Art. 113(b)))
    Legal practice
    Reaches legal-AI vendors or public bodies — GPAI providers serving legal markets can seek judicial review and benefit from procedural safeguards.
    See
    Court of Justice of the European Union · Art. 98(2) · Art. 101(6)

Cite

Regulation (EU) 2024/1689, Article 101 (Fines for providers of general-purpose AI models), as amended by Regulation (EU) 2026/1744, consolidated text of 27 July 2026, https://eur-lex.europa.eu/eli/reg/2024/1689/2026-07-27/eng#art_101 — text © European Union; only the Official Journal is authentic. Coding: SafeLegalAI (published by Cognesio LLP), "EU AI Act, structured", safelegalai.com/regulation/eu-ai-act/article-101, accessed 2026-09-08, CC BY 4.0.