§ EU AI Act · Article 99
AI Act Article 99: Obligations, Deadlines & Penalties
At a glance
Article 99 of the AI Act imposes 15 obligations on Member States, authorised representatives, deployers and 5 other entity type(s). At least one obligation carries an explicit compliance deadline. Non-compliance may result in administrative fines or other penalties.
§ Obligations
All obligations under Article 99
Obligation 1
Member States shall lay down rules on penalties and other enforcement measures applicable to infringements by operators, ensuring they are effective, proportionate, and dissuasive while considering SME interests.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
establish
- Deadline
-
—
- Penalty
-
—
Obligation 2
Member States shall take all measures necessary to ensure that the rules on penalties and enforcement measures are properly and effectively implemented.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
ensure
- Deadline
-
—
- Penalty
-
—
Obligation 3
Member States shall notify the Commission of the rules on penalties and other enforcement measures without delay and at the latest by the date of entry into application.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
notify
- Deadline
-
date of entry into application
- Penalty
-
—
Obligation 4
Member States shall notify the Commission without delay of any subsequent amendment to the rules on penalties and other enforcement measures.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
notify
- Deadline
-
without delay
- Penalty
-
—
Obligation 5
Operators must comply with the prohibition of AI practices referred to in Article 5 to avoid administrative fines of up to 35 million EUR or 7% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
operators
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 35 000 000 EUR or 7% of total worldwide annual turnover
Obligation 6
Providers must comply with obligations pursuant to Article 16 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
providers
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 7
Authorised representatives must comply with obligations pursuant to Article 22 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
authorised representatives
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 8
Importers must comply with obligations pursuant to Article 23 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
importers
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 9
Distributors must comply with obligations pursuant to Article 24 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
distributors
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 10
Deployers must comply with obligations pursuant to Article 26 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
deployers
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 11
Notified bodies must comply with requirements and obligations pursuant to Articles 31, 33(1), (3), (4), or 34 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
notified bodies
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 12
Providers and deployers must comply with transparency obligations pursuant to Article 50 to avoid administrative fines of up to 15 million EUR or 3% of total worldwide annual turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
providers, deployers
- Action required
-
comply
- Deadline
-
—
- Penalty
-
up to 15 000 000 EUR or 3% of total worldwide annual turnover
Obligation 13
Operators must not supply incorrect, incomplete, or misleading information to notified bodies or national competent authorities in reply to a request, under penalty of fines up to 7.5 million EUR or 1% of turnover.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
operators
- Action required
-
provide accurate information
- Deadline
-
—
- Penalty
-
up to 7 500 000 EUR or 1% of total worldwide annual turnover
Obligation 14
Member States shall lay down rules on the extent to which administrative fines may be imposed on public authorities and bodies established in that Member State.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
establish
- Deadline
-
—
- Penalty
-
—
Obligation 15
Member States shall report to the Commission on an annual basis about the administrative fines issued during that year and any related litigation or judicial proceedings.
Regulation (EU) 2024/1689, Article 99, Article 99
- Obligated entity
-
Member States
- Action required
-
report
- Deadline
-
annual basis
- Penalty
-
—
§ Deadlines
EU AI Act compliance deadlines
-
2025-02-02
Article 4 AI literacy
in_force
-
2025-02-02
Article 5 prohibitions (unacceptable risk)
in_force
-
2025-08-02
GPAI model obligations (Articles 51 to 56)
in_force
-
2026-08-02
Article 50(2) machine-readable marking (watermarking) of AI-generated content
provisionally_amended
-
2026-08-02
Article 50 transparency obligations OTHER than the 50(2) marking grace (for example disclosure that a user is interacting with an AI system)
scheduled
-
2026-08-02
Annex III stand-alone high-risk obligations
provisionally_amended
-
2026-08-02
National AI regulatory sandboxes (establishment deadline)
provisionally_amended
-
2026-12-02
NEW Article 5 prohibition: AI generation of non-consensual intimate imagery (NCII) and CSAM
provisionally_amended
-
2027-08-02
Annex I embedded (regulated-product) high-risk obligations
provisionally_amended
§ Frequently asked
Questions about Article 99
Who must comply with Article 99 of the AI Act?
+
Member States, authorised representatives, deployers, distributors, importers, notified bodies, operators, providers.
What does Article 99 of the AI Act require?
+
establish ensure notify
What is the compliance deadline for AI Act Article 99?
+
annual basis; date of entry into application; without delay
What are the penalties for non-compliance with AI Act Article 99?
+
up to 15 000 000 EUR or 3% of total worldwide annual turnover; up to 35 000 000 EUR or 7% of total worldwide annual turnover