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AI Act fines land on a stale register

3 min read
10:16UTC

The Commission gained the power to fine general-purpose AI model providers on 2 August. Its own list of national contact points still carries a footer reading 'Last update: 26 September 2025', with three member states blank.

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Key takeaway

Brussels can now fine model providers, yet three member states list no regulator to file with.

The European Commission became able on 2 August to fine a general-purpose AI model provider up to EUR 15,000,000 or 3 per cent of annual worldwide turnover, whichever is higher, under Article 101 of the EU AI Act. We pointed readers to that date in April, when we first reported the provision and the ceiling . What April could not show was what the enforcement network would look like when the date arrived, and the answer sits on the Commission's own website. The list of national single points of contact Brussels is obliged to publish carries a footer reading "Last update: 26 September 2025" 1.

Denmark, Finland and Hungary each get a hyphen where a contact point should sit, and the Cyprus row carries a hyperlink whose address contains text pasted out of the Spain row 2. Article 70, read with Article 113, required every member state to designate a market surveillance authority and a notifying authority and to publish contact details electronically by 2 August 2025. The same article puts a duty on Brussels: "the Commission shall make a list of the single points of contact publicly available" 3. That page hangs off a governance and enforcement section the Commission itself refreshed on 31 July 2026.

A company seeking a Danish, Finnish or Hungarian regulator to file with therefore has nowhere on the Commission's page to write to. The AI Act tracker maintained by the Future of Life Institute, an independent non-profit and not a Commission register, recorded at its 17 June 2026 update that 9 of 27 member states had designated both required authorities, 12 had partial arrangements, and 6 had designated neither: Austria, Belgium, Bulgaria, Croatia, Estonia and Greece 4. Those figures are seven weeks old and we have not extended them to August. Tracker and Commission also contradict each other on the three blank rows, which sit in the tracker's fully designated column 5.

Two qualifications stand between the new power and an actual fine. Article 111(3) gives providers of general-purpose models "placed on the market before 2 August 2025" until 2 August 2027 to comply with the Regulation 6, so the model families a reader could name by brand stay outside the enforceable set, and any first case concerns something launched in the past twelve months. The AI Office has also signalled a collaborative, risk-based approach before penalties. Article 101 itself runs to six paragraphs, gives a provider the right to be heard before any fine lands, and leaves the Court of Justice of the European Union unlimited jurisdiction to review or vary the amount 7.

Deep Analysis

In plain English

The European Union's AI Act now lets regulators fine companies that break AI rules, starting 2 August. But the Commission's own webpage listing which national office to contact in each EU country is out of date, with three countries' details missing entirely and one country's link showing text copied from another. It is a bit like a country announcing a new speeding fine but leaving the sign for where to send your complaint pointing at the wrong police station. The fine power itself works regardless; it is the administrative paperwork around it that has not caught up.

Deep Analysis
Root Causes

Article 70 assigns the register upkeep to the Commission but sets no penalty or audit trigger for staleness, so the obligation carries no enforcement teeth of its own; unlike the fine ceiling in Article 99, which has a number attached, register accuracy has none.

The Cyprus row's pasted Spain text points to a manual, non-templated update process: a spreadsheet or CMS field edited by hand rather than one populated from a single member-state submission schema, the kind of process failure that compounds every time a national authority's designation status changes.

First Reported In

Update #14 · AI Act fines arrive, three states list no regulator

AI Act tracker, Future of Life Institute· 4 Aug 2026
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Causes and effects
This Event
AI Act fines land on a stale register
A regulation becomes enforceable only where a company can find out who enforces it, and on the day the fining power commenced three member states offered no published address.
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