On February 9, the CNIL took stock—calmly reflecting on every moment of its remarkable year in 2025—and provided us with a very interesting overview of its activities over the past year.
First, a few figures! In 2025, the CNIL issued 259 decisions, including:
- 83 sanctions
- 143 formal notices
- 31 reminders of legal obligations
- 2 warnings
- 486,839,500 euros in cumulative fines
By comparison, in 2024, the CNIL issued 331 decisions, including 87 sanctions, 180 formal notices, and 64 reminders of legal obligations, for a cumulative fine total of “only” 55,212,400 euros.
Fewer decisions but nearly as many sanctions and a skyrocketing total in fines: the CNIL was hard at work in 2025 and took strong action to ensure respect for individuals’ rights.
The Commission remained focused on the issues it holds dear and, in particular, issued a significant number of sanctions in the following areas:
- Compliance with applicable rules regarding cookies and other trackers: this issue accounts for no fewer than 21 of the 83 sanctions and €475,000,000 in fines! Since the applicable rules have been known for several years, the CNIL has tended to become increasingly uncompromising.
For the record, on this topic, we commented in a previous article in our newsletter on the CNIL’s decision sanctioning the French subsidiary of American Express.
- Compliance with the applicable framework regarding employee video surveillance – This was particularly the case in September 2025, when La Samaritaine was fined 100,000 euros—a ruling we commented on at the time
- The obligations of processors, reminding – as it was previously done in october 2023 – them that they must (i) process data only upon instruction from the (ii) implement appropriate technical and organizational measures to ensure an adequate level of security, and (iii) delete the data upon termination of their contractual relationship with the data controller.
In 2025, the CNIL thus demonstrated consistency and an increasingly firm stance regarding the sanctions imposed.
There is no doubt that it will continue on this path in 2026.