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AI law comparison · Data verified 2026-08-22

EU AI Act — GPAI Rules vs GDPR Article 22

EU AI Act — GPAI Rules and GDPR Article 22 are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.

Find which laws apply to my business

Side by side

Attribute
EU AI Act — GPAI Rules
GDPR Article 22
Region
EU
EU
Effective date
2025-08-02
2018-05-25
Enforcement begins
Who must comply
The GPAI provisions create a two-tier compliance structure. Tier 1 — GPAI Model Providers: organizations that train or fine-tune foundation models (LLMs, multimodal models) and make them available to downstream integrato…
GDPR Art. 22 applies to: (1) any organization established in the EU/EEA; (2) organizations outside the EU/EEA that offer goods or services to EU/EEA data subjects or monitor their behavior. The "solely automated" thresho…
Maximum penalty
€15,000,000 or 3% of global annual turnover (for GPAI model provider violations)
€20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5))
Compliance requirements
5 tracked
5 tracked
Enforcement actions on record
1
2
Data last verified
2026-08-22
2026-08-22

Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.

The key difference

GDPR Article 22 takes effect first, so it is usually the more urgent of the two. EU AI Act — GPAI Rules tracks 5 compliance requirements and GDPR Article 22 tracks 5. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.

EU

EU AI Act — General-Purpose AI (GPAI) Obligations (Art. 50-55) + GPAI Code of Practice

As of August 2, 2025, the EU AI Act's obligations for General-Purpose AI (GPAI) model providers and deployers are in full effect (Chapter V, Articles 50-55). Organizations that integrate GPAI models (LLMs, image generators, multimodal AI) into their products must maintain technical documentation, implement copyright compliance policies, publish training data transparency summaries, and disclose AI-generated content t…

Full EU AI Act — GPAI Rules requirements
EU

EU GDPR Article 22 — Automated Decision-Making & AI Profiling

GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…

Full GDPR Article 22 requirements

Common questions

Could both EU AI Act — GPAI Rules and GDPR Article 22 apply to my business?

Yes. EU AI Act — GPAI Rules and GDPR Article 22 are separate regulations with separate scopes — a business can fall under both at once. EU AI Act — GPAI Rules covers The GPAI provisions create a two-tier compliance structure. GDPR Article 22 covers GDPR Art. If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.

Which has the higher maximum penalty — EU AI Act — GPAI Rules or GDPR Article 22?

EU AI Act — GPAI Rules: €15,000,000 or 3% of global annual turnover (for GPAI model provider violations) GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.

When does each law take effect?

EU AI Act — GPAI Rules — effective 2025-08-02. GDPR Article 22 — effective 2018-05-25. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.

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