European regulators have imposed 114 million euros ($126 million) in fines for data breaches since tougher privacy rules came into force in mid-2018, with approaches varying widely from country to country.

A report by law firm DLA Piper said France has imposed the biggest single fine – of 50 million euros against Google GOOGL.O – while the Netherlands, Britain and Germany led in terms of the number of data breach notifications.

The General Data Protection Regulation was introduced in an effort to safeguard sensitive personal information and prescribes stiff penalties if companies lose control of data or process it without proper consent.

It is enforced by a patchwork of national data protection offices across the 28-member European Union, with responsibility falling disproportionately on Ireland – the ‘lead’ regulator for Silicon Valley giants that have based their European operations there, such as Facebook FB.O.

The fines to date pale in comparison to multibillion-euro penalties imposed in EU anti-trust cases, but they are likely to rise over time as appeals and litigation subject the sanctions to scrutiny and create legal precedents.

In principle, regulators can impose fines of 2% or, in some cases 4%, of global turnover. In practice, they will have to judge whether such a heavy penalty would stand up in court, said DLA Piper partner Ross McKean.

“It’s going to take time – the regulators are going to be wary about going to 4% because they are going to get appealed,” McKean told Reuters. “And you lose credibility as a regulator if you’re blown up on appeal.”

The largest single penalty threatened so far has been in Britain, where the regulator has proposed a fine of 183 million pounds ($239 million) against British Airways owner IAG ICAG.L over the theft of data of half a million customers.

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