The European Commission has issued the first enforcement action under the EU AI Act. An €18 million fine against a Dutch recruitment platform that shipped a high-risk hiring system into the EU market without a fundamental rights impact assessment, and with bias testing the Commission described as materially incomplete. The decision, published on 4 April 2026, is the first under Article 99 since the Act's high-risk obligations bit on 2 August 2025. Three findings drove the size of the fine. No fundamental rights impact assessment on file at deployment. Bias testing limited to a single protected attribute, with no intersectional analysis. And operator-side logging that the regulator's auditors could not reconstruct from the records held. The platform has indicated it will appeal. The signal is the part [Australian operators](/grc/australia-no-ai-act-existing-law-compliance) should read closely. The Commission is not waiting for harm. The penalty is being sized off documentation gaps alone. If you are deploying high-risk AI into the EU under the Brussels effect, the next audit conversation just got more expensive.
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