Chapters 3 and 6The addressee
The turnover is that of the undertaking as a single economic unit, so the consolidated group turnover where there is a group (paras 120 to 122, 130). Use the financial year preceding the final decision (para 131).
Steps 1 to 4Infringements
Group infringements into conducts. Infringements of the same or linked processing operations form one conduct, and their total cannot exceed the highest legal maximum among them (Art. 83(3), paras 39 to 43). Separate conducts are fined separately and can exceed a single maximum (para 45). If one infringement precludes another (specialty, subsidiarity, consumption), keep only the superseding one (para 31).
Step 3Aggravating and mitigating circumstances
Chapter 5 gives no percentages and says none can be predetermined (para 71). Use this checklist to document the direction of each factor, then enter the net adjustment in each infringement above. Art. 83(2)(a), (b) and (g) are already priced into the seriousness level, so do not count them again (para 72).
Step 5Effectiveness, proportionality, dissuasiveness
A final check on the whole fine. Increase it if it is not dissuasive enough, for example with a deterrence multiplier (para 144), or reduce it for proportionality or inability to pay, which needs exceptional circumstances and objective evidence (paras 139 to 141). Do not repeat the turnover-based adjustment already made in Step 2 (para 64). The result is capped at the legal maximum (para 134).