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Requirement · PEN-02

Do not set a maximum limit on pecuniary penalties in national law that would prevent supervisory authorities imposing penalties in line with Art. 27(1)-(2)

Addressee Member StatesAct COM(2025) 81, 2025/0045 (COD)Article Art. 4(11), replacing Art. 27(4) of Directive (EU) 2024/1760Class Governments

What changes

Member States gain a new binding floor under national penalty caps; companies facing enforcement in Member States that previously set low caps may face steeper penalties.

Prior rule vs new rule

Prior rule
Obligation

Article 27(2) of that Directive requires Member States, when deciding whether to impose penalties and, if so, when determining their nature and appropriate level, to take due account of a series of factors that determine the gravity of the infringement and attenuating or aggravating circumstances.

New rule
Obligation

Do not set a maximum limit on pecuniary penalties in national law that would prevent supervisory authorities imposing penalties in line with Art. 27(1)-(2)

Who is affected

Addressee
Member States
Class
Governments
Sectors
No sector named — applies by size or activity
Applies
Once transposed by Member States (transposition due within 12 months of this Directive's entry into force)

Burden drivers

D6 — 1 of 7 marks fire on this provision.

Binds Member States, not a company by size.

Source text

Verbatim

Member States shall not set a maximum limit of pecuniary penalties in their national law transposing this Directive that would prevent supervisory authorities from imposing penalties in accordance with the principles and factors set out in paragraphs 1 and 2.

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