[M2Ys4U]

No. It's part of the calculation for the maximum fine.

The maximum fine is defined as €20,000,000 or 4% of your global anual turnover, whichever is largest.

[donovanh]

Yep

> Up to €20 million, or 4% of the worldwide annual revenue of the prior financial year, whichever is higher

https://www.gdpreu.org/compliance/fines-and-penalties/