AI Act fines land on a stale register

The European Commission became able on 2 August to fine a general-purpose AI model provider up to €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 row⁠². 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 Greece⁠⁴. 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 column⁠⁵.

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 Regulation⁠⁶, 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 amount⁠⁷.