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EU AI Act Article 101: fines for GPAI model providers
Article 101 gives the European Commission — not national authorities — the power to fine providers of general-purpose AI models directly, for breaches of the GPAI-specific chapter.
What triggers a fine
The Commission may fine a GPAI provider up to 3% of its total worldwide annual turnover in the preceding financial year, or 15 million euro, whichever is higher, where it intentionally or negligently infringes the relevant provisions of the Regulation (Articles 53, 54 and 55 — documentation, downstream information, copyright policy, training-data summary, and systemic-risk duties), fails to comply with a request for documents or information, supplies incorrect, incomplete or misleading information to the Commission, or fails to comply with a measure requested under Article 93.
How this differs from Article 99
Article 99 is the general penalty regime that Member States' national authorities apply to providers and deployers of AI systems generally — up to 7% of global turnover or 35 million euro for breaches of prohibited practices under Article 5, and up to 3% or 15 million euro for other high-risk obligations, with lower caps for SMEs and startups. Article 101 is narrower and specific to the Commission's own, centralised enforcement of the GPAI chapter (Articles 53-55) against model providers, reflecting the AI Office's direct oversight of a small number of large models.
Who it applies to
Providers of general-purpose AI models — the entities in scope of Article 53 and Article 55 — not deployers or downstream integrators, and not providers of high-risk AI systems built on top of a GPAI model, who fall under Article 99 instead.
Gaps to state honestly
Fine amounts are ceilings the Commission applies case by case, weighing the nature, gravity and duration of the infringement; this guide states the caps in the Regulation, not a prediction of any actual fine. Use our penalty calculator to estimate general Article 99 exposure for AI system providers and deployers.
How Vetro helps
Vetro cannot reduce Article 101 exposure for a GPAI provider — that depends on the provider's own documentation and disclosures to the Commission. If you are a downstream deployer or integrator worried about your own Article 99 exposure, Vetro's hash-chained, ed25519-signed ledger and Vetro Attest — free verification, 29 USD counter-signed report — give you evidence of what your own system did. Not legal advice.
See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.