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Enforcement May 15, 2026 8 min

Vodafone Germany fined EUR 45 million: the Art. 28 GDPR lesson on processor controls

BfDI June 2025 - 15M for failed control of partner sales agents, 30M for weak MeinVodafone authentication. What changes for DPOs managing processor chains

TL;DR for the DPO

June 2025: BfDI fines Vodafone Germany for EUR 45M. 15M for Art. 28 GDPR (failure to control partner sales agents who defrauded customers with fictitious contracts), 30M for Art. 32 (weaknesses in MeinVodafone portal authentication allowing unauthorized eSIM access). Lesson: the controller cannot delegate responsibility to the processor. Continuous control, not just contractual, is required.

The facts

Vodafone GmbH uses a network of partner agencies that sell phone contracts under Vodafone's brand. Despite being legally separate entities, they operate under Vodafone's brand, use hardware and software provided by Vodafone, and are bound to Vodafone's instructions via Data Processing Agreements. They therefore qualify as processors under Art. 28 GDPR.

15MEUR
Art. 28 fine
30MEUR
Art. 32 fine
45MEUR
Total fine

Key principle: accountability is not delegable

BfDI explicitly stated that outsourcing processing activities does not outsource GDPR responsibility. The controller remains responsible for the conduct of its processors and must demonstrate it with documentary evidence: periodic audits, inspections, security reports received from the processor, records of non-conformities and corrective actions.

Official source:BfDI - Vodafone decision (EDPB)

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