Methodology & Contacts
The small print for the report.
21 May 2026
Montenegro
3 min read
The small print for the ET Report reads as follows:
- The ET Report is based on the fines included in the Enforcement Tracker. The Enforcement Tracker only contains publicly available fines. As we are aware that DPA policies relating to the publication of fines vary between DPA/jurisdictions, we know that the content of the Enforcement Tracker, and hence the basis for the ET Report, is inevitably incomplete. However, this approach is the only available option so far, and we will continue to work on this basis.
- The Enforcement Tracker considers fines from all EU Member States as well as from the UK.
- This 7th edition of the ET Report covers all fines from 2018 up to the editorial deadline of 1 March 2026. As of the editorial deadline of 1 March 2026, the Enforcement Tracker covered 3,062 fines (+502) in comparison to the GDPR Enforcement Tracker Report 2025). The only exception to the deadline is the implementation of the Luxembourg Administrative Court's decision to overturn the EUR 746 million fine imposed on Amazon Europe Core S.à.r.l., due to the significance of this ruling.
- The reference period of the 7th ET Report (all publicly known fines up to 1 March 2026) refers to the date when the fines are recorded in the database, not when they were imposed by the authority.
- The aim of this Enforcement Tracker Report is to categorise and analyse the identified fines. However, some DPAs have issued fines to unknown controllers, or an unknown amount, or in an unknown sector. Such fines have not been included in the numbers & figures section of the ET Report. This anonymity of some fines also explains the discrepancy between the overall number/amount of fines included in the Enforcement Tracker (3,062 as of 1 March 2026) and those we have included in this Enforcement Tracker Report (2,685 as of 1 March 2026).
- Each fine is assigned to only one sector (business sector or “Employment”) depending on the main focus of the data processing. For fines that could be allocated to several sectors, we have taken a focal point approach and placed more specific sectors ahead of more general sectors (e.g. Industry & Commerce).
- All fines in the Enforcement Tracker are assigned a unique and permanent “ETid”. These ETids are also used by the ET Report when referring to specific fines – the details of a case are just a click away.
No risks or secondary effects have been brought to our attention so far. If you detect something odd, suspicious or otherwise worth reporting while reading the ET Report or using the Enforcement Tracker, please feel free to reach out to us.
