Interesting wrinkle of the EU Chat Control 2.0 proposal: the maximum penalty for non-compliance is a % of the penalized entity's turnover (aka revenue).
If I'm reading this right, for a service that collects no payment and does not generate turnover in any other way (such as advertising), the maximum penalty is therefore zero.
See page 258 of the December 2025 draft: https://data.consilium.europa.eu/doc/document/ST-16495-2025-INIT/en/pdf
Explains why Dr Breyer says https://www.patrick-breyer.de/en/posts/chat-control/#currentproposal that non-remunerated services are out of scope.
If I'm reading this right, for a service that collects no payment and does not generate turnover in any other way (such as advertising), the maximum penalty is therefore zero.
See page 258 of the December 2025 draft: https://data.consilium.europa.eu/doc/document/ST-16495-2025-INIT/en/pdf
Explains why Dr Breyer says https://www.patrick-breyer.de/en/posts/chat-control/#currentproposal that non-remunerated services are out of scope.
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