November 1, 2024 GB confirmed
United Kingdom (ICO): sceptical of fines as a tool
The UK Information Commissioner was an outlier in 2024, with very few fines. Its head, John Edwards, said in November 2024 that he does not believe fines have the greatest impact and that they would tie his office up in years of litigation. After Brexit, the UK applies its own version of the GDPR with a deliberately less punitive philosophy.
March 1, 2026 SE confirmed
Sweden (IMY): consults and warns before imposing fines
The Swedish authority follows a different approach from the big sanctioners: it prioritizes consultation and issues reprimands or warnings before imposing fines. Its cumulative amount is low, not from inaction, but from regulatory philosophy: the financial penalty is the last resort, not the first.
August 1, 2024 NL confirmed
Netherlands (AP): forceful, selective fines
The Dutch authority applies forceful though less numerous sanctions: in August 2024 it imposed a €290 million fine, one of the year's largest in Europe. It prioritizes systemic cases over volume.
March 1, 2026 LU confirmed
Luxembourg (CNPD): second by amount, but its largest fine was annulled
The Luxembourg authority accumulates around €746 million, almost all from a single sanction: the 2021 Amazon fine for advertising without valid consent. That fine was annulled on procedural grounds by the Luxembourg Administrative Court in March 2026, though the underlying violations were upheld. It is the perfect example of the gap between announced and final amount.
March 1, 2026 IT confirmed
Italy (Garante): active by volume and attentive to AI
Italy's Garante is one of the most active authorities by number of sanctions (41 in 2024, third in the EU) and has been a pioneer in acting against AI services over data processing. It combines sanctions on large and mid-sized firms in sectors such as utilities and telecoms.
March 1, 2026 IE confirmed
Ireland (DPC): the authority concentrating more than half the total amount
Ireland's Data Protection Commission leads by far: around €4.04 billion cumulative, over 50% of the European total, and 9 of the 10 largest GDPR fines. Its dominance is structural: Meta, Google, TikTok, LinkedIn, Apple and Microsoft have their European headquarters in Dublin, making it the lead authority under the one-stop-shop. Largest fine ever: Meta, €1.2 billion (2023).
March 1, 2026 FR confirmed
France (CNIL): overtook Luxembourg and is the most aggressive on cookies and ad-tech
France's CNIL overtook Luxembourg in 2025 and is the second authority besides Ireland to exceed €1 billion cumulative. It has been the most aggressive on cookie consent and advertising: in September 2025 it imposed €325 million on Google and €150 million on Shein.
March 1, 2026 ES confirmed
Spain (AEPD): leader by number of fines, but with low average amounts
The Spanish Data Protection Agency is Europe's most active by volume: nearly 1,000 fines since 2018, the continent's highest count. But its average amount is far below other authorities. It is the opposite of Ireland: it sanctions a lot and cheaply, versus Ireland which sanctions little and huge. By number of fines in 2024 it led with 107, followed by Romania and Italy.
January 1, 2025 DE confirmed
Germany: decentralized enforcement among regional authorities
Germany is a particular case: its enforcement is split among the data-protection authorities of each Land (federal state), plus the federal one. This produces a relevant volume of sanctions (around €45.9 million in the analyzed 2024 period) but dispersed, without Ireland's concentration nor Spain's unit volume.