TL;DR for the DPO
18 March 2026: the Rome Court (judgment 4153/2026) annuls the Garante's 2024 decision fining OpenAI EUR 15M. The Court treats JURISDICTION as decisive: cross-border processing like ChatGPT's falls under the one-stop-shop, with the lead authority (in the EU, the Irish DPC). The substantive claims are not decided.
The facts
In 2024 the Garante alleged several violations (legal basis for training, notice, age verification, breach notification) and fined OpenAI EUR 15M plus a mandatory awareness campaign. OpenAI appealed; after a 2025 stay, the March 2026 judgment annulled the decision on jurisdiction grounds.
Not a clean bill of health for ChatGPT
The ruling does not certify ChatGPT's GDPR compliance: it only decides who had power to sanction. Obligations for companies using ChatGPT are unchanged.
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