Skip to content
Welcome, thoughtbot's Giant Robots listeners!Start here
Russia-Ukraine War 2026
12OCT

AI Act fines land on a stale register

3 min read
10:59UTC

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.

ConflictDeveloping
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 €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.

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
Read original →
Different Perspectives
Government of Latvia
Government of Latvia
Latvia abstained on 22 September when the EU renewed its individual sanctions for 36 months at the price of delisting Alisher Usmanov and Mikhail Fridman, and promised national sanctions of its own. Riga's abstention marks how far a frontline member state will go to keep listed names listed.
India's Ministry of External Affairs
India's Ministry of External Affairs
After the House passed the Graham bill on 16 September, India's foreign ministry said it would keep buying energy on market terms and protect its trade. Russia supplied 30.3% of India's crude imports in fiscal 2026, so the tariff decision due around 18 October falls directly on New Delhi.
Kaja Kallas, EU foreign policy chief
Kaja Kallas, EU foreign policy chief
Kallas answered the US licence on 10 October by saying Europe would not ease pressure, and EU ministers adopted a 22nd package of nearly 1,600 listings two days later. Brussels is tightening as Washington loosens, though TASS reported the package adds no significant new trade restrictions.
Donald Trump and the US Treasury
Donald Trump and the US Treasury
The Treasury licensed Russian diesel imports until 7 April 2027 on the day of Trump's call with Putin, and Trump then told reporters Ukraine should find a new leader. Washington is trading sanctions relief for fuel supply while pressing Kyiv to halt the refinery strikes behind the shortage.
Kremlin and Deputy Prime Minister Alexander Novak
Kremlin and Deputy Prime Minister Alexander Novak
After the 9 October call the Kremlin said Russia was ready to supply oil and petroleum products to American and global markets, and Novak brought forward the end of diesel export curbs. Moscow is selling the shortage back as goodwill, with volumes that Decree No. 686 now hides from outside checks.
Volodymyr Zelenskyy, President of Ukraine
Volodymyr Zelenskyy, President of Ukraine
Zelenskyy called GL 135 an investment in prolonging the war and offered to stop striking Russian refineries if Russia stops destroying Ukraine's energy system. Answering Trump's call for a new leader, he set a total 60-day ceasefire as the condition for elections, which puts the next move on Moscow.