{
 "$schema_version": "1.0.0",
 "$description": "Enforcement actions. Three orthogonal status axes: action_status (what the authority did and whether it stands), payment_status (whether money moved), remedy_status (whether behaviour changed). Nothing in this schema permits 'fine imposed' to imply 'fine collected'.",
 "$last_verified": "2026-08-27",
 "$note": "null means the question has not been researched. 'unknown' means it has been researched and is not publicly determinable. These are different states and must never be rendered alike. No aggregate totals are stored here: any total shown to a user is computed from these records at render time. The pipeline stages shown in the interface are DERIVED from these fields by a documented rule set (js/pipeline.js), not stored, so no stage can be asserted that the record does not support. A stage the record cannot settle is Unknown, and Unknown is never counted as zero. AUDIT-2026-09-25 (2026-09-26): records re-read individually against their sources carry that date in their own last_verified; this file's $last_verified is deliberately unchanged, because the file as a whole was not re-read, and moving it would assert that it was.",
 "enforcement": [
  {
   "id": "enf-uber-ap-2026",
   "entity": "Uber Technologies Inc.",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-22",
    "gdpr:art-83"
   ],
   "authority": "dpa-nl",
   "opened": null,
   "decision_date": "2026-08-21",
   "action": "Administrative fine for fully automated deactivation of drivers (Art. 22 GDPR) and insufficient information about it",
   "fine_eur": 824990000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:implemented",
   "behavioural_outcome": "The authority states that Uber has stopped the violations.",
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-ap-uber-2026"
   ],
   "sources": [
    "src-ap-uber-2026"
   ],
   "requires_verification": false,
   "verification_note": "Added 27 Sep 2026 from the Autoriteit Persoonsgegevens' English release of 21 August 2026 (the decision date is taken as the release date; the release gives no separate adoption date). Lead authority under the one-stop-shop after 171 French drivers complained through the Ligue des droits de l'Homme to the CNIL. The decision itself was not opened. Re-read 23 Oct 2026: the AP's release (page last edited 21 Aug 2026) still states every value recorded here, including that Uber has appealed. No later AP statement on Uber was found; Dutch court records were not searched, so a ruling on the appeal would not have been seen.",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Uber",
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "The authority's release: 'Uber has filed an appeal against the fine.' Forum and case number are not stated."
   }
  },
  {
   "id": "enf-uber-ap-2024",
   "entity": "Uber Technologies Inc. and Uber B.V.",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-83"
   ],
   "authority": "dpa-nl",
   "opened": null,
   "decision_date": "2024-08-26",
   "action": "Administrative fine for transferring European drivers' data to the US without appropriate safeguards (Chapter V GDPR)",
   "fine_eur": 290000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:implemented",
   "behavioural_outcome": "The authority states that Uber has ended the violation.",
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-ap-uber-2024"
   ],
   "sources": [
    "src-ap-uber-2024",
    "src-ap-uber-2026"
   ],
   "requires_verification": false,
   "verification_note": "Added 27 Sep 2026 from the Autoriteit Persoonsgegevens' English release of 26 August 2024; the decision date is taken as the release date (CMS's database gives 22 July 2024, which was not confirmed on the authority's page). Legal basis records Art. 83 only, because no Chapter V provision record exists. Re-read 23 Oct 2026: the AP's releases of 26 Aug 2024 and 21 Aug 2026 still state every value recorded here, the later one that the procedures on this fine are ongoing. Dutch court records were not searched, so a ruling on the appeal would not have been seen.",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Uber",
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "The authority's release of 21 August 2026: 'Uber defends itself against the last two fines; the procedures on this matter are still ongoing.'"
   }
  },
  {
   "id": "enf-amazon-cnpd-2021",
   "entity": "Amazon Europe Core S.à r.l.",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-6",
    "gdpr:art-83"
   ],
   "authority": "dpa-lu",
   "opened": null,
   "decision_date": "2021-07-15",
   "action": "Administrative fine",
   "fine_eur": 746000000,
   "action_status": "action:annulled",
   "payment_status": "payment:not-payable",
   "remedy_status": "remedy:implemented",
   "behavioural_outcome": "Amazon now relies on user consent rather than legitimate interest for the disputed advertising processing; at the hearing of 8 January 2026 both parties, including the CNPD, confirmed it was compliant, so the 2021 compliance orders and daily penalty became moot.",
   "judicial": {
    "forum": "Cour administrative (Luxembourg)",
    "date": "2026-03-12",
    "outcome": "The CNPD's decision was annulled in all its parts and the file remitted to the CNPD: it had not examined fault (intent or at least negligence), which the CJEU requires (C-807/21 Deutsche Wohnen and C-683/21 Nacionalinis: the GDPR sets no strict liability), and it had treated a fine as the only option, without weighing the other measures available under Art. 58. On the merits the Court confirmed, for the practices at the start of the investigation, that Art. 6(1)(f) was not a sufficient legal basis and that Arts 12–14 were breached, and confirmed Arts 15–17 subject to the reservation that rectification and erasure were at risk rather than shown to be infringed; it held that the investigation's scope did not cover Arts 16 and 21. The CNPD itself declared its injunctions moot, the last changes it asked for having been made. Judgment of 12 March 2026 (ECLI:LU:CADM:2026:52757), published 13 March 2026.",
    "case_ref": "52757C (du rôle), ECLI:LU:CADM:2026:52757",
    "remitted": true
   },
   "timeline_events": [],
   "claims": [
    "clm-amazon-annulment",
    "clm-announced-vs-collected"
   ],
   "sources": [
    "src-lu-cadm-52757c-judgment",
    "src-mlex-2026-amazon-annulment",
    "src-linarilaw-2026-amazon",
    "src-justice-lu-amazon-2026",
    "src-paperjam-amazon-2026",
    "src-cms-lu-enforcement-2026"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27 against the judgment itself (Cour administrative, 52757C, 12 March 2026, 89 pages, read in full text from the Luxembourg administrative courts' site). It confirms the CNPD decision of 15 July 2021, the EUR 746,000,000 fine with a daily penalty of EUR 746,000, the grounds of annulment, the findings on the merits and the injunctions becoming moot, which supports remedy:implemented. The judgment is pseudonymised ('(AA)'); that the appellant is Amazon Europe Core rests on the Luxembourg judiciary's announcement of 13 March 2026 and the press reports that name it. The CNPD decision date was corrected from 16 to 15 July 2021 on 2026-09-26 and is confirmed by the judgment.",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:decided",
    "lodged_by": "Amazon Europe Core S.à r.l.",
    "forum": "Cour administrative (Luxembourg)",
    "lodged_date": "2025-04-25",
    "case_ref": "52757C (du rôle)",
    "note": "Appeal lodged on 25 April 2025 against the judgment of the tribunal administratif of 18 March 2025 (no. 46578 du rôle), which had dismissed the challenge to the CNPD decision. Decided 12 March 2026: the decision annulled in all its parts and the file remitted. The Cour administrative describes itself in the judgment as the second and last instance. What the CNPD does on remittal is not established."
   }
  },
  {
   "id": "enf-meta-dpc-2023-transfers",
   "entity": "Meta Platforms Ireland Limited",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-83"
   ],
   "authority": "dpa-ie",
   "opened": null,
   "decision_date": "2023-05-12",
   "action": "Administrative fine and order to suspend EU-US transfers (Art. 46(1) GDPR infringed)",
   "fine_eur": 1200000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-dpc-share-of-fines"
   ],
   "sources": [
    "src-dpc-meta-transfers-2023",
    "src-dpc-annual-report-2023",
    "src-csoonline-alliance-risk-2026",
    "src-oj-t325-23-meta-edpb-action",
    "src-curia-register-2026-09-27"
   ],
   "requires_verification": true,
   "verification_note": "Added 2026-09-26 (audit T-36) from the DPC's announcement: decision of 12 May 2023, announced 22 May 2023; Art. 46(1) infringed; fine reflecting the EDPB's binding determination under Art. 65. Legal basis records Art. 83 only, because no Art. 46 provision record exists. Appeal state, 27 Sep 2026: that the DPC decision was appealed to the Irish High Court is now established by the DPC itself (Annual Report 2023); the pending General Court action against the EDPB decision (T-325/23) is established from the Court's register. Still flagged because the Irish appeal's CURRENT state is not: the DPC's later reports and its judgments page (read 27 Sep 2026) record no judgment in it, which is not a record that it is still pending.",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Meta Platforms Ireland Limited",
    "forum": "High Court of Ireland (statutory appeal); also judicial review in the High Court, and T-325/23 before the General Court against the EDPB",
    "lodged_date": null,
    "case_ref": null,
    "note": "The DPC's Annual Report 2023 states that 'the Final Decision is under appeal' and that Meta brought three challenges: a statutory appeal before the Irish High Court, judicial review proceedings before the High Court, and annulment proceedings against the EDPB. The last is Case T-325/23, brought on 13 June 2023 (OJ 2023/C 271/47) against the EDPB's Binding Decision 1/2023, and recorded as pending in the Court's register on 27 Sep 2026. No record number or lodging date for the Irish proceedings has been read, and no judgment in them appears on the DPC's list of judgments (read 27 Sep 2026); CSO Online (29 May 2026, tier 4) reports the appeal as active."
   }
  },
  {
   "id": "enf-tiktok-dpc-2025-transfers",
   "entity": "TikTok Technology Limited",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-83"
   ],
   "authority": "dpa-ie",
   "opened": null,
   "decision_date": "2025-04-30",
   "action": "Administrative fines and order to bring China transfers into compliance within six months (Arts. 46(1) and 13(1)(f) GDPR infringed)",
   "fine_eur": 530000000,
   "action_status": "action:appealed",
   "payment_status": "payment:not-payable",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": {
    "forum": "High Court of Ireland (Commercial), Mulcahy J",
    "date": "2026-06-03",
    "outcome": "Main judgment of 3 June 2026: every ground against the two infringement findings (Art. 46(1), 29 July 2020 to 17 May 2023; Art. 13(1)(f), 29 July 2020 to 1 December 2022) and against the decision to impose fines to be dismissed; the DPC made no error of law in holding that a controller must verify, and be able to demonstrate, essentially equivalent protection for data transferred. The court found errors in the DPC's assessment of material relevant to the suspension order (an unconsidered expert opinion on Chinese law; no reasons given for rejecting TikTok's Project Clover measures) and proposed to vacate the corrective orders and remit them to the DPC, subject to hearing the parties on the final form of order. The amount of the fines was left over: by a second judgment of 30 June 2026 ([2026] IEHC 419) the court held the DPC entitled, subject to the CJEU's answers, to use ByteDance's turnover and 2024 as the preceding financial year, and proposed four questions for a preliminary reference on Art. 83.",
    "case_ref": "Record No. 2025/248 MCA; [2026] IEHC 347; [2026] IEHC 419"
   },
   "timeline_events": [],
   "claims": [
    "clm-dpc-share-of-fines"
   ],
   "sources": [
    "src-dpc-tiktok-transfers-2025",
    "src-iehc-2026-347-tiktok",
    "src-iehc-2026-419-tiktok",
    "src-curia-register-c1009-26"
   ],
   "requires_verification": false,
   "verification_note": "Added 2026-09-26 (audit T-36) from the DPC's announcement of 2 May 2025. Re-read 27 Sep 2026 against the High Court's two approved judgments, which replace the tier-4 reporting the appeal state rested on. Corrected: the decision is dated 30 April 2025 ([2026] IEHC 347 §6), not 2 May 2025, which is the announcement date. Payment is recorded as not yet payable because the appeal stayed it automatically under s. 142 of the Data Protection Act 2018 (§14). Legal basis records Art. 83 only, because no Art. 46 or Art. 13 provision record exists.",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "TikTok Technology Limited and TikTok Information Technologies UK Limited",
    "forum": "High Court of Ireland (Commercial)",
    "lodged_date": "2025-05-27",
    "case_ref": "2025/248 MCA",
    "note": "Statutory appeal under ss. 142 and 150 of the Data Protection Act 2018, by originating notice of motion of 27 May 2025 ([2026] IEHC 347 §11). Partly decided: the infringement findings and the decision to fine stand ([2026] IEHC 347, 3 June 2026). Still open: the amount of the fines, on which the court proposed a reference to the CJEU ([2026] IEHC 419, 30 June 2026), and the final form of the order on the corrective orders, which the court proposed to vacate and remit; that order itself has not been read. The corrective orders were stayed pending the appeal ([2025] IEHC 619), a stay the Supreme Court continued ([2026] IESC 27). The CJEU register holds a pending reference named for the same two companies, C-1009/26, lodged 11 Sep 2026; its referring court is not given in the entry read, so the link is not established."
   }
  },
  {
   "id": "enf-openai-garante-2024",
   "entity": "OpenAI",
   "entity_type": "actor:large-company",
   "instrument": "gdpr",
   "legal_basis": [
    "gdpr:art-83"
   ],
   "authority": "dpa-it",
   "opened": "2023-03",
   "decision_date": "2024-11-02",
   "action": "Administrative fine",
   "fine_eur": 15000000,
   "action_status": "action:annulled",
   "payment_status": "payment:not-payable",
   "remedy_status": "remedy:none",
   "behavioural_outcome": "unknown",
   "judicial": {
    "forum": "Tribunale di Roma",
    "date": "2026-03-18",
    "outcome": "Annulled on a preliminary, jurisdictional ground (as analysed by the European Law Blog; the judgment's text has not been read here): once OpenAI Ireland was recognised by the Irish DPC as OpenAI's single EEA establishment (15 February 2024), the DPC became lead authority under the one-stop-shop. Some twenty months of investigation, from March 2023 to the November 2024 decision, ended with no court ruling on whether the conduct was lawful.",
    "case_ref": "Tribunale di Roma, judgment no. 4153/2026 (R.G. 4785/2025)"
   },
   "timeline_events": [],
   "claims": [
    "clm-openai-fine-voided",
    "clm-one-stop-shop"
   ],
   "sources": [
    "src-garante-openai-2024",
    "src-europeanlawblog-openai-rome"
   ],
   "requires_verification": true,
   "verification_note": "Corrected 2026-09-27 from the Garante's own website. The decision is no. 755 of 2 November 2024 (doc-web 10085455); 20 December 2024, recorded here before, is the date of the Garante's press release announcing it (doc-web 10085432), which confirms the EUR 15 million fine, the six-month information campaign ordered under Art. 166(7) of the Italian Privacy Code, an investigation opened in March 2023, and the transfer of the file to the Irish DPC as lead authority once OpenAI established its European headquarters in Ireland. The same notice records that the Court of Rome's judgment no. 4153/2026, published 18 March 2026, upheld OpenAI's opposition. STILL OPEN: the judgment itself has not been read, so its ground — recorded as a jurisdiction point under the one-stop-shop — rests on academic analysis (European Law Blog). CORRECTED 27 Sep 2026: the judicial outcome and the Part II prose (all four languages) said 'nine months of investigative work', which the Garante's own account contradicts — the investigation opened in March 2023 and the decision is of 2 November 2024, some twenty months. Both now say so. (Nine months is roughly the span from OpenAI Ireland's recognition, 15 February 2024, to the decision; the text did not say that, so it is not kept.)",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:decided",
    "lodged_by": "OpenAI",
    "forum": "Tribunale di Roma",
    "lodged_date": null,
    "case_ref": null,
    "note": "Decided: the Garante's own notice (read 27 Sep 2026) states that the Court of Rome's judgment no. 4153/2026, published 18 March 2026, upheld OpenAI's opposition to decision no. 755, and that the decision has been temporarily removed from the Garante's website. Whether the Garante has appealed is not established."
   }
  },
  {
   "id": "enf-x-ec-2025",
   "entity": "X (Twitter)",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-25",
    "dsa:art-39",
    "dsa:art-40",
    "dsa:art-74"
   ],
   "authority": "ec",
   "opened": null,
   "decision_date": "2025-12-05",
   "action": "Non-compliance decision and fine; action plan accepted by the Commission on 16 July 2026 (six months to implement, then an independent audit). The acceptance does not replace the decision, which X is challenging.",
   "fine_eur": 120000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": "unknown",
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-x-fine",
    "clm-x-data-access-staffing",
    "clm-press-release-governance",
    "clm-x-action-plan",
    "clm-x-preliminary-findings-2024"
   ],
   "sources": [
    "src-ec-x-fine-2025",
    "src-eucrim-x-first-fine",
    "src-ec-x-decision-2025-house-release",
    "src-euperspectives-x-appeal-2026",
    "src-doj-x-intervention-2026",
    "src-oj-t114-26-x-action",
    "src-oj-t120-26-xai-action",
    "src-oj-t121-26-musk-action",
    "src-curia-register-2026-09-27",
    "src-ec-x-action-plan-2026",
    "src-ec-x-preliminary-2024"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27. Amount and the three grounds from the Commission press release; decision number, date and case numbers from the three Official Journal notices of the actions against it, which also establish the appeals (T-114/26, T-120/26, T-121/26, lodged 16 Feb 2026) and the Court's register (pending, 27 Sep 2026). The per-infringement fines and the 183 pages rest on the decision text as released by the US House Judiciary Committee, not by the Commission. Two framings belong to the linked claims, not to this record, and remain unconfirmed there: the seventeen-month gap from preliminary findings, and 'first DSA fine'. 14 Oct 2026: the Commission's acceptance of X's action plan (16 July 2026) read that day and added; it follows the decision and withdraws nothing, so action_status stays imposed and the appeals stay pending. behavioural_outcome moved from null (not researched) to unknown (researched, not publicly determinable): implementation was due within six months of acceptance and no audit result has been published. The Commission's press release, re-read that day, calls this 'the first non-compliance decision under the DSA'. The appeal state was not re-read on 14 Oct 2026; it is as of 27 Sep 2026.",
   "last_verified": "2026-10-14",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "X Internet ulc and X Holdings Corp. (T-114/26); X.AI Holdings LLC (T-120/26); Elon Musk (T-121/26)",
    "forum": "General Court of the European Union",
    "lodged_date": "2026-02-16",
    "case_ref": "T-114/26; T-120/26; T-121/26",
    "note": "Three actions for annulment of the Decision of 5 December 2025 in Cases DSA.100101–100103 (C(2025) 8630 final), all brought on 16 February 2026 (OJ C/2026/2390, 2391 and 2392 of 4 May 2026, read on 27 Sep 2026). The decision is addressed to more than one person: X.AI Holdings and Mr Musk each ask, in the alternative, for annulment insofar as it is addressed to them. All three recorded as pending in the Court's register on 27 Sep 2026. Whether the US Department of Justice's application to intervene (24 Sep 2026) has been admitted is not established."
   }
  },
  {
   "id": "enf-temu-ec-2026",
   "entity": "Temu",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-34",
    "dsa:art-74"
   ],
   "authority": "ec",
   "opened": "2024-10-31",
   "decision_date": "2026-05-28",
   "action": "Non-compliance decision and fine (risk assessment, Art. 34); action plan due by 28 August 2026 under Art. 75",
   "fine_eur": 200000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-temu-fine"
   ],
   "sources": [
    "src-ec-temu-fine-2026",
    "src-techpolicypress-temu",
    "src-curia-register-2026-09-27"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27 against IP/26/1178, read in full: EUR 200 million on 28 May 2026; formal proceedings opened 31 October 2024; preliminary findings July 2025; the breach found is of the risk-assessment obligation (Art. 34) only, so Art. 35 is removed from the legal basis it was wrongly listed under; action plan due by 28 August 2026 (Art. 75). 'Largest DSA fine to date' was commentary and is in any case superseded by AliExpress (EUR 550 million, 20 July 2026). The appeal state is left unknown: the register holds T-536/26 Whaleco Technology v Commission (12 Aug 2026), whose subject is not yet published. 21 Oct 2026 (audit item 5): re-checked. The Commission press corner was searched for the company on 21 Oct 2026 and holds no release after the fine on the action plan, a Board opinion or a final decision under Art. 75; the deadline line of the fine release was re-read. The Commission's DSA pages (digital-strategy.ec.europa.eu) and the Court's register could not be read from this environment that day (HTTP 403; InfoCuria answers only to its browser application), so the appeal state is as read on 27 Sep 2026. The remedy stays remedy:ordered: the decision orders it and nothing read records it implemented. The action-plan deadline of 28 August 2026 has passed; whether a plan was submitted is not published, and on the timetable in IP/26/1178 (one month for the Board, a further month for the Commission) a final decision could fall due around the end of October 2026 if a plan was submitted on time.",
   "last_verified": "2026-10-21",
   "appeal": {
    "status": "appeal:unknown",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Not established. The Court's register lists Case T-536/26 Whaleco Technology v Commission, lodged 12 August 2026 and pending (read 27 Sep 2026). The register gives no subject matter and the Official Journal notice of the action was not yet held by the Publications Office, so whether it challenges this decision is not established."
   }
  },
  {
   "id": "enf-aliexpress-ec-2026",
   "entity": "AliExpress",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-34",
    "dsa:art-35",
    "dsa:art-74"
   ],
   "authority": "ec",
   "opened": "2024-03-14",
   "decision_date": "2026-07-20",
   "action": "Non-compliance decision and fine (risk assessment and mitigation, Arts 34 and 35); action plan due by 20 October 2026",
   "fine_eur": 550000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-aliexpress-fine"
   ],
   "sources": [
    "src-ec-aliexpress-fine-2026",
    "src-curia-register-2026-09-27"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27 against IP/26/1654, read in full: EUR 550 million on 20 July 2026 for failing to diligently assess AND mitigate systemic risks from illegal, unsafe and counterfeit products; formal proceedings opened 14 March 2024; commitments on other grievances made binding and preliminary findings adopted on 18 June 2025; action plan due by 20 October 2026, now from the Commission's own text rather than commentary. The appeal state is left unknown: AliExpress said it would challenge the decision (Lewis Silkin, 24 July 2026), and no action appeared in the Court's register by 27 Sep 2026. 14 Oct 2026: the action-plan deadline of 20 October 2026 re-read in the full press release IP/26/1654. Whether a plan has been submitted, and the appeal state, were not re-checked that day. 21 Oct 2026 (audit item 5): re-checked. The Commission press corner was searched for the company on 21 Oct 2026 and holds no release after the fine on the action plan, a Board opinion or a final decision under Art. 75; the deadline line of the fine release was re-read. The Commission's DSA pages (digital-strategy.ec.europa.eu) and the Court's register could not be read from this environment that day (HTTP 403; InfoCuria answers only to its browser application), so the appeal state is as read on 27 Sep 2026. The remedy stays remedy:ordered: the decision orders it and nothing read records it implemented. The action-plan deadline of 20 October 2026 has passed; whether a plan was submitted is not published.",
   "last_verified": "2026-10-21",
   "appeal": {
    "status": "appeal:unknown",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "AliExpress announced its intention to challenge the decision (reported by Lewis Silkin, 24 July 2026); no case number located. The Court's register, read 27 Sep 2026, lists no action by the company lodged after the decision of 20 July 2026; the time limit runs from notification, whose date is not published, so this is the register's state on that date and not a finding that no action will be brought."
   }
  },
  {
   "id": "enf-tiktok-ec-2025-commitments",
   "entity": "TikTok",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-39"
   ],
   "authority": "ec",
   "opened": null,
   "decision_date": "2025-12-05",
   "action": "Commitments made binding",
   "fine_eur": null,
   "action_status": "action:commitments",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-commission-prefers-compliance"
   ],
   "sources": [
    "src-ec-tiktok-commitments-2025"
   ],
   "requires_verification": false,
   "verification_note": "Ad-repository failings cured by binding commitment rather than fine. Whether the commitments have been implemented is not established.",
   "last_verified": "2026-08-27",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Closed by binding commitments. There is no penalty decision to appeal."
   }
  },
  {
   "id": "enf-tiktok-ec-2026-addictive",
   "entity": "TikTok",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-34",
    "dsa:art-35"
   ],
   "authority": "ec",
   "opened": "2024-02-19",
   "decision_date": "2026-02-06",
   "action": "Preliminary findings",
   "fine_eur": null,
   "action_status": "action:announced",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:unknown",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-first-architecture-enforcement"
   ],
   "sources": [
    "src-ec-tiktok-addictive-2026"
   ],
   "requires_verification": false,
   "verification_note": "Preliminary findings are not a decision. Infinite scroll, autoplay and personalised recommenders — platform architecture rather than illegal content. 14 Oct 2026: opening date from IP/26/1679 (24 July 2026), which names these addictive-design findings as part of the formal proceedings opened 19 February 2024; the February 2026 release itself was not re-read.",
   "last_verified": "2026-10-14",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Preliminary findings are not a decision and are not appealable."
   }
  },
  {
   "id": "enf-meta-ec-2026-under13",
   "entity": "Meta (Instagram and Facebook)",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-28",
    "dsa:art-34",
    "dsa:art-35"
   ],
   "authority": "ec",
   "opened": "2024-05-16",
   "decision_date": "2026-04-29",
   "action": "Preliminary findings: minors under 13 on Instagram and Facebook",
   "fine_eur": null,
   "action_status": "action:announced",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:unknown",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [],
   "sources": [
    "src-ec-meta-under13-2026",
    "src-ec-meta-minors-opening-2024"
   ],
   "requires_verification": false,
   "verification_note": "Registered 21 Oct 2026 (audit item 3) from IP/26/920, read in full that day. Preliminary findings are not a decision. The breach found at this stage: Meta fails 'to diligently identify, assess and mitigate the risks of minors under 13' accessing the services, with no effective check on self-declared birth dates, an ineffective reporting tool and an 'incomplete and arbitrary' risk assessment. The release names no article: the legal basis is the one the opening release IP/24/2664 gives for these proceedings (Arts 28, 34 and 35), which the findings' wording tracks (risk assessment and mitigation; 'a high level of privacy, safety and security for minors'). Not a fine: if confirmed, up to 6% of worldwide turnover.",
   "last_verified": "2026-10-21",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Preliminary findings are not a decision and are not appealable."
   }
  },
  {
   "id": "enf-meta-ec-2026-addictive",
   "entity": "Meta (Instagram and Facebook)",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-34",
    "dsa:art-35"
   ],
   "authority": "ec",
   "opened": "2024-05-16",
   "decision_date": "2026-07-10",
   "action": "Preliminary findings",
   "fine_eur": null,
   "action_status": "action:announced",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:unknown",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [],
   "sources": [
    "src-ec-meta-addictive-2026"
   ],
   "requires_verification": false,
   "verification_note": "Preliminary findings are not a decision. Proposed remedies include disabling autoplay and infinite scroll by default. 14 Oct 2026: read with the full press release IP/26/1579. Formal proceedings opened 16 May 2024; 'These preliminary findings do not prejudge the final outcome of the investigation.' The Commission's view at this stage is that Meta needs design changes, for instance disabling autoplay and infinite scroll by default. Not a decision and not a fine: if confirmed, a non-compliance decision could carry a fine of up to 6% of worldwide turnover.",
   "last_verified": "2026-10-14",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Preliminary findings are not a decision and are not appealable."
   }
  },
  {
   "id": "enf-tiktok-ec-2026-minors",
   "entity": "TikTok",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [
    "dsa:art-34",
    "dsa:art-35"
   ],
   "authority": "ec",
   "opened": "2024-02-19",
   "decision_date": "2026-07-24",
   "action": "Preliminary findings",
   "fine_eur": null,
   "action_status": "action:announced",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:unknown",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [],
   "sources": [
    "src-ec-tiktok-minors-2026"
   ],
   "requires_verification": false,
   "verification_note": "Preliminary findings are not a decision. Minors' accounts default to public; 16–17 year-olds' content recommended in the For You feed. 14 Oct 2026: read with the full press release IP/26/1679. Preliminary findings in the formal proceedings opened 19 February 2024 — the same proceedings in which the February 2026 addictive-design findings (enf-tiktok-ec-2026-addictive) were adopted. They are separate findings on separate issues within one proceeding, not a separate investigation, and neither is a decision.",
   "last_verified": "2026-10-14",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Preliminary findings are not a decision and are not appealable."
   }
  },
  {
   "id": "enf-apple-ec-2025",
   "entity": "Apple",
   "entity_type": "actor:gatekeeper",
   "instrument": "dma",
   "legal_basis": [
    "dma:art-5",
    "dma:art-30"
   ],
   "authority": "ec",
   "opened": "2024-03-25",
   "decision_date": "2025-04-23",
   "action": "Non-compliance decision and fine under Art. 5(4)",
   "fine_eur": 500000000,
   "action_status": "action:appealed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": "EU iPhone users can set rival browsers and payment apps as defaults, install applications outside the App Store, and use third-party payment solutions.",
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-apple-proactive-enablement",
    "clm-dma-consumer-benefit-modest"
   ],
   "sources": [
    "src-ec-apple-meta-dma-2025",
    "src-oj-t438-25-apple-action",
    "src-curia-register-2026-09-27",
    "src-curia-register-2026-10-23"
   ],
   "requires_verification": true,
   "verification_note": "Updated 2026-09-27. The appeal is now established from the Official Journal notice of the action (Case T-438/25, lodged 7 July 2025) and the Court's register (pending on 27 Sep 2026); the investigation's opening date, 25 March 2024, is from the Commission's press release IP/25/1085, read in full the same day. STILL OPEN: the behavioural outcome recorded here reproduces the author's interpretation (clm-dma-consumer-benefit-modest) and is not what this decision is about — the press release describes a steering infringement under Art. 5(4) and an order to remove technical and commercial restrictions on steering within 60 days; it says nothing about default browsers, installation outside the App Store or third-party payment. The same release closed the separate investigation into Apple's user-choice obligations. Establishing what changed for users after this decision needs a Commission compliance assessment, which has not been read. Re-read 23 Oct 2026: IP/25/1085 (through the Commission's press-corner API) and the OJ notice of T-438/25 (C/2025/5215, through the Publications Office) carry every value above; the Court's register (InfoCuria search service) still records T-438/25 as 'Affaire pendante'. The open question on the behavioural outcome is unchanged: no Commission compliance assessment was found, and the DMA site lists none since 23 July 2026.",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Apple Inc.",
    "forum": "General Court of the European Union",
    "lodged_date": "2025-07-07",
    "case_ref": "T-438/25",
    "note": "Action for annulment of Decision C(2025) 2090 final (case DMA.100109), or annulment or reduction of the fine, brought on 7 July 2025 (OJ C/2025/5215, read in the Official Journal on 27 Sep 2026). Recorded as pending in the Court's register on 27 Sep 2026."
   }
  },
  {
   "id": "enf-meta-ec-2025",
   "entity": "Meta",
   "entity_type": "actor:gatekeeper",
   "instrument": "dma",
   "legal_basis": [
    "dma:art-5",
    "dma:art-30"
   ],
   "authority": "ec",
   "opened": "2024-03-25",
   "decision_date": "2025-04-23",
   "action": "Non-compliance decision and fine under Art. 5(2)",
   "fine_eur": 200000000,
   "action_status": "action:appealed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": "On 8 December 2025 the Commission acknowledged Meta's undertaking to give EU users, from January 2026, a choice between fully personalised advertising and a less-personalised option sharing less data; the Commission said it would then seek evidence on uptake.",
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-meta-pay-or-consent"
   ],
   "sources": [
    "src-ec-apple-meta-dma-2025",
    "src-ec-meta-ad-choice-2025",
    "src-oj-t435-25-meta-action",
    "src-curia-register-2026-09-27",
    "src-curia-register-2026-10-23"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27. Decision, date, fine and ground from the Commission's press release IP/25/1085 (read in full): the binary 'Consent or Pay' model did not give users the specific choice of an equivalent service using less personal data, for the period March–November 2024; investigation opened 25 March 2024. The appeal from the Official Journal notice of Case T-435/25 and the Court's register. The behavioural outcome from the Commission's statement of 8 December 2025. The brief's 'three-tier advertising model' was replaced on 2026-09-26 (audit T-18) by that statement's two-way choice. Re-read 23 Oct 2026: IP/25/1085, the Commission's statement of 8 December 2025 and the OJ notice of T-435/25 (C/2025/5214) carry every value above; the Court's register still records T-435/25 as 'Affaire pendante'. The DMA site lists no later Commission statement on Meta's ad model (read 23 Oct 2026).",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Meta Platforms, Inc.",
    "forum": "General Court of the European Union",
    "lodged_date": "2025-07-04",
    "case_ref": "T-435/25",
    "note": "Action for annulment of the Decision of 23 April 2025 in Case DMA.100055 Meta – Article 5(2) DMA, and annulment or reduction of the fine, brought on 4 July 2025 (OJ C/2025/5214, read in the Official Journal on 27 Sep 2026). Recorded as pending in the Court's register on 27 Sep 2026."
   }
  },
  {
   "id": "enf-apple-gc-2026-designation",
   "entity": "Apple",
   "entity_type": "actor:gatekeeper",
   "instrument": "dma",
   "legal_basis": [
    "dma:art-3"
   ],
   "authority": "gc",
   "opened": null,
   "decision_date": "2026-07-08",
   "action": "Judgment dismissing gatekeeper-designation challenges",
   "fine_eur": null,
   "action_status": "action:imposed",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:none",
   "behavioural_outcome": null,
   "judicial": {
    "forum": "General Court of the European Union",
    "date": "2026-07-08",
    "outcome": "Apple's designation challenges dismissed in full. App Store and iOS obligations confirmed; iMessage pleas held inadmissible; App Store versions treated as a single core platform service. Closes the route by which designated gatekeepers could contest interoperability obligations at the designation stage, but leaves the substance of Art. 6(7) untested.",
    "case_ref": "Joined Cases T-1079/23, T-1080/23 and T-214/24, ECLI:EU:T:2026:451"
   },
   "timeline_events": [],
   "claims": [
    "clm-gc-apple-designation-upheld"
   ],
   "sources": [
    "src-gc-apple-designation-2026",
    "src-gc-t1079-23-judgment"
   ],
   "requires_verification": false,
   "verification_note": "Judicial outcome checked on 27 Sep 2026 against the judgment itself (ECLI:EU:T:2026:451): operative part point 2 dismisses the actions; paras 47 and 62 hold the plea of illegality against Art. 6(7) inadmissible at the designation stage; para 99 rejects the plea against treating the App Stores as a single core platform service; para 133 holds the iMessage plea inadmissible; para 148 dismisses the actions in T-1079/23 and T-214/24 as inadmissible. Whether an appeal to the Court of Justice has been lodged is still not established (see appeal.note). Until 27 Sep 2026 action_status read action:final, which the unknown appeal contradicts; it reads action:imposed and the pipeline shows its final stage as unknown rather than reached.",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:unknown",
    "lodged_by": null,
    "forum": "Court of Justice of the European Union",
    "lodged_date": null,
    "case_ref": null,
    "note": "Not established. Rechecked on 15 Oct 2026 in the Court's case register (InfoCuria, https://infocuria.curia.europa.eu/, whose index that day held cases lodged up to 7 Oct 2026 and a closure dated 14 Oct 2026): T-1079/23, T-1080/23 and T-214/24 are recorded as closed on 8 July 2026, joined, with no appeal linked to any of them, and no case with Apple as a party was lodged after 8 July 2026. The same was found on 27 Sep 2026. An appeal lies within two months of notification of the judgment, extended by ten days on account of distance (Statute of the Court of Justice, Art. 56; Rules of Procedure, Art. 51). Had the judgment been notified on the day it was delivered, that period would have ended on 18 September 2026; the register does not show the notification date, so appeal:not-lodged is still not recorded."
   }
  },
  {
   "id": "enf-supervisory-fee-gc-2025",
   "entity": "Meta Platforms Ireland and TikTok Technology",
   "entity_type": "actor:vlop",
   "instrument": "dsa",
   "legal_basis": [],
   "authority": "gc",
   "opened": null,
   "decision_date": "2025-09-10",
   "action": "Annulment of the DSA supervisory-fee implementing decisions",
   "fine_eur": null,
   "action_status": "action:annulled",
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:none",
   "behavioural_outcome": null,
   "judicial": {
    "forum": "General Court of the European Union",
    "date": "2025-09-10",
    "outcome": "The implementing decisions setting the supervisory fee were annulled because the methodology should have been adopted by delegated act. Effects provisionally maintained, for no more than twelve months from the date on which the judgments become final; the Commission's appeals are pending, so that period has not started. This is an annulment of the fee decisions, not of the fee mechanism as such.",
    "case_ref": "Cases T-55/24 Meta Platforms Ireland and T-58/24 TikTok Technology"
   },
   "timeline_events": [],
   "claims": [
    "clm-gc-supervisory-fee-annulled"
   ],
   "sources": [
    "src-gc-supervisory-fee-2025",
    "src-mlex-2025-dsa-fee-appeal",
    "src-mlex-2026-dsa-fee-appeal-oj",
    "src-oj-c744-25p-fee-appeal",
    "src-oj-c745-25p-fee-appeal",
    "src-curia-register-2026-09-27",
    "src-curia-register-2026-10-23"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27. The judgments from the Court's press release; the appeals from the two Official Journal notices (C-744/25 P and C-745/25 P, lodged 20 Nov 2025), which name the contested acts at first instance — Implementing Decisions C(2023) 8176 final (Facebook and Instagram) and C(2023) 8173 final (TikTok) of 27 November 2023 — and the Court's register (pending, 27 Sep 2026). This supersedes the MLex reports of 24 Nov 2025 and 12 Jan 2026, which are kept as the record of how the appeal was first learned of. Re-read 23 Oct 2026: Press Release No 114/25, both Official Journal notices and the Court's register (both appeals still pending). The outcome above was corrected on the author's decision of 24 Oct 2026: it read 'for up to twelve months', which drops the press release's condition that the twelve months run from the date the judgments become final.",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "European Commission",
    "forum": "Court of Justice of the European Union",
    "lodged_date": "2025-11-20",
    "case_ref": "C-744/25 P (against T-55/24, Meta Platforms Ireland); C-745/25 P (against T-58/24, Tiktok Technology)",
    "note": "Both appeals brought on 20 November 2025 (OJ C/2026/164 and C/2026/165 of 12 January 2026, read on 27 Sep 2026). The Commission asks the Court of Justice to set aside the judgments and give final judgment, or refer the cases back. Recorded as pending in the Court's register on 27 Sep 2026."
   }
  },
  {
   "id": "enf-google-ec-2025-adtech",
   "entity": "Google",
   "entity_type": "actor:gatekeeper",
   "instrument": "tfeu",
   "legal_basis": [
    "tfeu:art-102"
   ],
   "authority": "ec",
   "opened": null,
   "decision_date": "2025-09-05",
   "action": "Antitrust decision and fine under Article 102 TFEU",
   "fine_eur": 2950000000,
   "action_status": "action:appealed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-dma-alongside-102"
   ],
   "sources": [
    "src-ec-google-adtech-2025",
    "src-oj-t794-25-google-action",
    "src-curia-register-2026-10-23"
   ],
   "requires_verification": false,
   "verification_note": "This is an Article 102 TFEU decision, NOT a DMA decision. Recorded here to keep the distinction visible: the DMA operates alongside Articles 101 and 102, not instead of them. Re-read 23 Oct 2026: the decision date, the fine, Article 102 and the order to end the practices from the Commission's release IP/25/1992 (through the press-corner API); the appeal from the Official Journal notice of Case T-794/25 (C/2026/185, through the Publications Office) and the Court's register (pending, 23 Oct 2026); recorded on the author's decision of 24 Oct 2026. CASE NUMBER NOT ESTABLISHED: IP/25/1992 gives AT.40670, the Official Journal notice AT.40760; both are primary sources and neither is preferred here. Payment is not stated in either.",
   "last_verified": "2026-10-23",
   "appeal": {
    "status": "appeal:pending",
    "lodged_by": "Google LLC and Alphabet Inc.",
    "forum": "General Court of the European Union",
    "lodged_date": "2025-11-20",
    "case_ref": "T-794/25",
    "note": "Action for annulment, in whole or in part, of the decision of 5 September 2025, and annulment or reduction of the fine, brought on 20 November 2025 (OJ C/2026/185, read on 23 Oct 2026); seventeen pleas, including against the finding of a single continuous infringement and against the measures required beyond the cease-and-desist order. Recorded as pending in the Court's register on 23 Oct 2026."
   }
  },
  {
   "id": "enf-hungary-commission-none",
   "entity": "Hungary",
   "entity_type": "actor:member-state",
   "record_type": "record-type:inaction",
   "instrument": "ai-act",
   "legal_basis": [
    "ai-act:art-5"
   ],
   "authority": "ec",
   "opened": null,
   "decision_date": null,
   "action": "No infringement proceedings opened",
   "fine_eur": null,
   "action_status": null,
   "payment_status": "payment:not-applicable",
   "remedy_status": "remedy:none",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [],
   "claims": [
    "clm-hungary-no-infringement",
    "clm-hungary-biometric-breach",
    "clm-enforcement-asymmetry"
   ],
   "sources": [
    "src-ecnl-hungary-ai-act",
    "src-edri-hungary-ai-act",
    "src-ec-infringement-package-2026-10"
   ],
   "requires_verification": true,
   "verification_note": "A NEGATIVE record: it asserts the absence of enforcement, which is true only at an instant. action_status is null because no action exists to describe. Civil-society legal analysis concluding a breach of AI Act Art. 5 and of the Charter is sourced; the absence of Commission action is corroborated by the same sources reporting continued calls for infringement proceedings, and no contrary evidence was found on 26 September 2026, after the April 2026 change of government in Hungary. This record must be re-verified on every publication. 21 Oct 2026 (audit item 7): re-checked against the Commission's fourteen monthly infringement packages from 12 March 2025 to 1 October 2026; none records a decision against Hungary on this basis. The register's own search could not be queried from this environment. 21 Oct 2026 (audit item 11): typed record-type:inaction, so that the observatory, the instrument pages and the masthead no longer count it as an enforcement record or draw it a pipeline.",
   "last_verified": "2026-10-21",
   "appeal": {
    "status": "appeal:none",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "No action exists, so no appeal can arise. This record asserts an absence."
   }
  },
  {
   "id": "enf-google-ec-2026-dma",
   "entity": "Google",
   "entity_type": "actor:gatekeeper",
   "instrument": "dma",
   "legal_basis": [
    "dma:art-5",
    "dma:art-6",
    "dma:art-30"
   ],
   "authority": "ec",
   "opened": "2024-03-25",
   "decision_date": "2026-07-23",
   "action": "Two non-compliance decisions and fines: EUR 460 million for self-preferencing in Google Search (Art. 6(5)) and EUR 430 million for anti-steering in Google Play (Art. 5(4)); compliance ordered within 60 days.",
   "fine_eur": 890000000,
   "action_status": "action:imposed",
   "payment_status": "payment:unknown",
   "remedy_status": "remedy:ordered",
   "behavioural_outcome": null,
   "judicial": null,
   "timeline_events": [
    "tl-dma-2026-07-23-enforcement"
   ],
   "claims": [
    "clm-google-dma-fine-2026",
    "clm-google-dma-largest-total",
    "clm-google-dma-search-fine",
    "clm-google-dma-play-fine"
   ],
   "sources": [
    "src-ec-google-dma-fine-2026",
    "src-ec-google-dma-fine-2026-ip",
    "src-curia-register-2026-09-27",
    "src-ec-google-dma-opening-2024"
   ],
   "requires_verification": false,
   "verification_note": "Verified 2026-09-27. IP/26/1670, read in full: two decisions on 23 July 2026, EUR 460 million (Search self-preferencing) and EUR 430 million (Play steering), compliance within 60 days, proceedings opened 25 March 2024, preliminary view 19 March 2025. The articles come from the opening release IP/24/1689, which names Art. 5(4) for Alphabet's steering rules and Art. 6(5) for self-preferencing on Google Search; the 2026 release says the decisions close those two investigations. The appeal state is left unknown: the release says Google 'may decide to appeal', and no action appeared in the Court's register by 27 Sep 2026.",
   "last_verified": "2026-09-27",
   "appeal": {
    "status": "appeal:unknown",
    "lodged_by": null,
    "forum": null,
    "lodged_date": null,
    "case_ref": null,
    "note": "Not established. Contemporary reporting described Google as considering an appeal; no filing is recorded here. The Court's register, read 27 Sep 2026, lists no action by the company lodged after the decision of 23 July 2026; the time limit runs from notification, whose date is not published, so this is the register's state on that date and not a finding that no action will be brought."
   }
  }
 ]
}