CNIL Simplified Sanctions Procedure: What Companies Need to Know in 2026

CNIL Simplified Sanctions Procedure: Understanding an Increasingly Used Enforcement Mechanism

Personal data protection is now a major concern for all organisations. With the continued increase in complaints submitted by data subjects, the CNIL has had to adapt its investigation and enforcement methods.

It was in this context that the CNIL simplified sanctions procedure was introduced in 2022. This mechanism allows the CNIL to deal more quickly with certain GDPR breaches.

Since its creation, the simplified procedure has become a widely used enforcement tool. Since January 2026, 23 new sanctions have been imposed under this procedure, 19 of which resulted from complaints.

For organisations, this development is a reminder that everyday data protection breaches can now lead to a faster enforcement procedure.

What Is the CNIL Simplified Sanctions Procedure?

The simplified sanctions procedure is an expedited enforcement procedure introduced by the CNIL to handle certain cases more efficiently.

It applies to situations that do not raise any particular legal or factual difficulties and where the facts can be assessed relatively straightforwardly.

The objectives are several:

• enable the CNIL to handle more cases;
• provide a faster response to complaints and reports;
• impose sanctions more quickly for common GDPR breaches.

Unlike the ordinary procedure, the decision is not issued by a collegiate panel. Instead, the president of the restricted committee, or another member of that committee, may decide on the sanction alone.

When Can the CNIL Use the Simplified Procedure?

The CNIL may use this procedure when a case does not present any particular legal or factual difficulty.

Several factors may be considered, including the simplicity of the facts established, the absence of a new legal issue and the existence of similar cases previously handled by the CNIL.

In practice, the simplified procedure is notably used to deal with recurring breaches such as:

• failure to respect data subject rights;
• employee video surveillance that does not respect privacy requirements;
• breaches of cookie rules;
• failure to cooperate with the CNIL.

These examples also correspond to the main categories of breaches identified by the CNIL in the simplified sanctions issued since January 2026.

Everyday GDPR Breaches Can Lead to Enforcement Action

The simplified procedure therefore shows that common GDPR breaches should not be considered secondary issues.

Video surveillance, cookies, the exercise of data subject rights and cooperation with the CNIL can all become areas of investigation and, in certain circumstances, lead directly to an administrative sanction.

How Does the CNIL Simplified Sanctions Procedure Work?

Although it is described as a “simplified” procedure, it remains a genuine enforcement procedure that respects the rights of defence.

Step 1: Opening of the Procedure

Following an investigation, complaint or report, the CNIL President may decide to refer the case to the simplified procedure.

A rapporteur is then appointed to investigate the case and analyse the evidence collected.

Step 2: Exchanges with the Organisation Concerned

The organisation concerned is informed of the allegations made against it and is given a period of time to submit its observations.

This stage is essential because it allows the organisation to:

• provide explanations;
• challenge certain elements;
• demonstrate corrective measures that have already been implemented;
• demonstrate its good faith or cooperation.

At the request of the organisation concerned, it may also be heard as part of a hearing before the president of the committee and the rapporteur.

Step 3: The CNIL's Decision

Once the investigation has been completed, the president of the restricted committee rules on the case.

The CNIL may notably impose:

• a formal warning;
• an order to comply;
• a periodic penalty payment;
• an administrative fine.

The simplified procedure therefore allows the CNIL to respond more quickly to certain breaches while maintaining a procedural framework in which the organisation concerned can submit its observations.

What Sanctions Can the CNIL Impose?

The main particularity of the simplified procedure concerns the amount of financial sanctions.

Under this procedure, an administrative fine cannot exceed €20,000. This limit distinguishes it from the ordinary procedure, under which sanctions can reach several million euros.

Another important difference is that the name of the sanctioned organisation is not made public under this procedure.

However, it would be misleading to consider this procedure insignificant.

Even a financially limited sanction can have significant consequences:

• mobilisation of internal teams;
• cost of corrective measures;
• time spent on compliance remediation;
• risk of subsequent investigations;
• need to review internal data protection procedures.

The CNIL also reported that the 23 simplified sanctions imposed since January 2026 represented a total of €133,750 in fines.

How Can Organisations Reduce the Risk of a CNIL Sanction?

The simplified sanctions procedure highlights the importance of maintaining effective and regularly monitored GDPR compliance.

Managing data subject rights requests, transparency towards data subjects, cookie compliance, video surveillance and the compliance of processing activities are all important areas of attention.

A GDPR compliance audit can help identify the main gaps and establish an appropriate remediation plan. DPO Consulting provides support to assess an organisation’s compliance level, identify risks and define priority corrective actions.

Discover DPO Consulting’s GDPR compliance audit services

For organisations seeking ongoing support, appointing an Outsourced DPO can also help structure compliance management, particularly when it comes to handling data subject rights requests, maintaining documentation and monitoring remediation actions.

Discover DPO Consulting’s Outsourced DPO services

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