Article 99 of Regulation (EU) 2024/1689 sets out three tiers of administrative fines, payable by AI operators that fail to comply with the regulation. The top tier — €35 million or 7% of worldwide annual turnover, whichever is higher — applies to violations of the Art. 5 prohibitions. The middle tier — €15 million or 3% — applies to violations of provider obligations (Art. 16), deployer obligations (Art. 26), and transparency under Art. 50, among others. The lower tier — €7.5 million or 1% — applies to supplying incorrect or misleading information to authorities. Chapter XII (penalties) applies from 2 August 2025 under Art. 113(b). For SMEs and start-ups, the lower of the two amounts applies, under Art. 99(6).
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Article 99 distributes liability across three bands. For undertakings, the fine is the higher of the absolute amount and the percentage of worldwide annual turnover. For SMEs and start-ups, Art. 99(6) reverses this: the lower of the two amounts applies.
Article 99(3). Non-compliance with the prohibition of the AI practices referred to in Article 5 shall be subject to administrative fines of up to €35,000,000 or, if the offender is an undertaking, up to 7% of total worldwide annual turnover for the preceding financial year — whichever is higher.
Article 99(4). Up to €15,000,000 or 3% of worldwide annual turnover, whichever is higher. Covers: provider obligations (Art. 16), authorised representatives (Art. 22), importers (Art. 23), distributors (Art. 24), deployers (Art. 26), notified bodies (Art. 31, 33(1)(3)(4), 34), and transparency obligations for providers and deployers (Art. 50).
Article 99(5). Supply of incorrect, incomplete or misleading information to notified bodies or national competent authorities in reply to a request: up to €7,500,000 or 1% of worldwide annual turnover, whichever is higher.
Article 100. The European Data Protection Supervisor may impose: up to €1,500,000 for non-compliance with Art. 5 prohibitions; up to €750,000 for other infringements.
Aggravating and mitigating factors (Art. 99(7)): nature, gravity, duration of infringement; whether other authorities have already fined for the same conduct; size, turnover, market share of the operator; previous infringements; degree of cooperation; intent or negligence; mitigation actions; and so on. Art. 99(10) requires appropriate procedural safeguards and effective judicial remedies.
There are three tiers under Art. 99. €35M / 7% (Art. 99(3)) only applies to violations of the Art. 5 prohibitions. Most of the day-to-day high-risk obligations — failing to produce technical documentation under Art. 11, failing to register, failing to implement QMS — are sanctioned under Art. 99(4) at €15M / 3%. Supplying wrong information to authorities is Art. 99(5) at €7.5M / 1%.
Chapter XII (Penalties) — including Art. 99 — applies from 2 August 2025 under Art. 113(b). From that date, fines can already be imposed for any obligation already in force, which includes the Art. 5 prohibitions (from 2 February 2025), Art. 4 AI literacy and the Chapter V GPAI obligations.
Art. 99(6) reverses the calculation for SMEs and start-ups: each fine referred to in Art. 99 shall be up to the percentages or amount referred to in 99(3), (4) and (5), whichever is lower. The percentage and absolute amount are still capped — only the choice between them flips.
Answer these four questions to determine your obligations.
12 PDF documents generated from your inputs. Each cites the article of Regulation (EU) 2024/1689 it fulfils.
Identifies whether your system is prohibited (Art. 5), high-risk (Art. 6 + Annex III) or subject to transparency obligations (Art. 50).
The 9 blocks of Annex IV in full: system description, training data, validation, performance metrics, risk management, human oversight. Art. 11 + Annex IV.
Signable document conforming to Art. 47 and Annex V.
Key application dates: 2 Feb 2025, 2 Aug 2025, 2 Aug 2026, 2 Aug 2027. Art. 113.
Executive summary of compliance status for authorities or commercial buyers. Art. 43 procedure.
QMS structure covering the 13 aspects required by Art. 17.
Document for the entity deploying your system, conforming to Art. 13.
Verifiable evidence list, cross-referenced to every Annex IV block.
Notification protocol conforming to Art. 73 (15 days general / 10 days death / 2 days widespread).
Training plan conforming to Art. 4, in force since 2 February 2025.
Plan structure required by Art. 72 and integrated into the technical documentation under Annex IV(9).
Template under Art. 27 for public bodies, private entities providing public services, and Annex III 5(b)(c) deployers.
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If your system falls under Art. 43(1) (Annex III point 1 biometrics with notified-body route, or Annex I products), you will need third-party conformity assessment. That is a separate process. AICheck does not replace it.
We do not sell audits. We do not sell consultancy. We sell the tool that structures your documentation under Annex IV.
Article 99 of Regulation (EU) 2024/1689. Chapter XII (Penalties) applies from 2 August 2025.
Art. 99(3). Up to €35 million or 7% of total worldwide annual turnover, whichever is higher. For SMEs and start-ups: whichever is lower (Art. 99(6)).
Art. 99(4). Includes failure to draw up technical documentation under Art. 11 + Annex IV. Covers obligations of providers (Art. 16), deployers (Art. 26), authorised representatives (Art. 22), importers (Art. 23), distributors (Art. 24), notified bodies (Art. 31, 33, 34) and transparency under Art. 50.
Art. 99(5). Applies when information provided to notified bodies or national competent authorities is wrong or misleading.
If you operate multiple AI systems and need to document them all under Annex IV, contact us for volume pricing at hello@solidwaretools.com.
Request volume pricingAICheck produces a document structured under Article 11 and Annex IV of Regulation (EU) 2024/1689 from the information you provide. The accuracy, truthfulness and completeness of that information is your responsibility as provider of the AI system.
We guarantee that the document structure follows Article 11 and Annex IV of Regulation (EU) 2024/1689 and that the legal references cited are correct as of the last verification date. We do not guarantee that a specific document will be accepted by a market surveillance authority in a given case, nor by a commercial buyer in a procurement process.
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Twelve documents. Annex IV fully structured. Regulation (EU) 2024/1689. Your data does not leave your machine. The ZIP you download is yours to keep.