GDPR Enforcement in 2025: Highlights from the EDPB Annual Report
In 2025, GDPR enforcement in Europe developed not only through fines, but also through cross-border cooperation, data subject rights and the interaction between digital regulations.
What’s in this article?
In 2025, GDPR enforcement in Europe developed not only through fines, but also through cross-border cooperation, data subject rights and the interaction between digital regulations.
This assessment uses official data from the European Data Protection Board’s (EDPB) 2025 Annual Report published on 9 April 2026. Rather than an unverified ranking of the “seven most frequently penalised issues”, we focus on the specific enforcement indicators reported by the EDPB.
Official EDPB Figures for 2025
According to the EDPB’s 2025 Annual Report:
- The EDPB case register recorded 414 cross-border cases.
- The One-Stop-Shop mechanism under Article 60 GDPR triggered 1,299 procedures.
- Of these, 572 reached a final decision.
- During 2025, national data protection authorities imposed fines totalling approximately €1.15 billion.
These figures alone do not establish which GDPR articles were penalised most frequently.
Cross-Border Enforcement
For digital products and SaaS services operating across several countries, data protection investigations may involve more than one national authority.
The One-Stop-Shop system is a key cooperation mechanism between the lead supervisory authority and the other supervisory authorities concerned in cross-border data processing.
2025 Coordinated Enforcement Framework
The EDPB’s coordinated enforcement work in 2025 focused on the right to erasure.
This shows why companies need more than a privacy policy: data subject requests must also be implementable in their actual systems.
Can Erasure Requests Be Implemented Technically?
When stating that a customer’s data has been deleted, its status must be known in:
- CRM,
- customer support systems,
- marketing automation systems,
- data warehouses,
- backup systems
The status of the data in each system must be known.
AI and GDPR Intersection
Throughout 2025, the EDPB worked on how data protection law interacts with AI and Europe’s other digital regulations.
Companies should not assess AI projects solely under the AI Act. If a system processes personal data, GDPR requirements on lawful basis, transparency, data minimisation and data subject rights also apply.
Operational Lessons from GDPR Enforcement in 2025
- The privacy policy must match actual system behaviour.
- Data subject requests should not be handled by the legal team alone.
- Requests for erasure, access and rectification must be linked to the relevant technical systems.
- Cross-border data streams must be visible.
- AI and profiling processes should be included in the data inventory.
- Compliance evidence must be retained in an auditable form.
A fine is not the only risk.
When assessing GDPR enforcement, do not focus solely on the amount of a fine.
Other consequences for companies include:
- Stopping processing activity,
- obligation to delete data,
- corrective measure,
- reputational impact,
- Operation Cost
These can also have significant consequences.
2025 GDPR Enforcement Checklist
- Can data subject requests be implemented in the systems?
- Are cross-border data flows documented?
- Has the scope of the One-Stop-Shop mechanism been assessed?
- Are AI systems included in the data inventory?
- Do retention and erasure processes work in the actual systems?
- Is evidence of compliance retained?
The B10 Approach
B10 Digital Agency considers legal requirements alongside actual data flows, SaaS systems and technical operations in GDPR and KVKK compliance work.
Official Source
European Data Protection Board – Annual Report 2025
Conclusion
The 2025 GDPR enforcement figures show that compliance is not just about drafting documents. Implementing data subject rights in actual systems and putting cross-border data management into practice are essential parts of corporate data governance.
