My understanding is that EUR 50 million is the max of the current sanction, but that the ACM can always just impose another set of sanctions if they feel Apple

My understanding is that EUR 50 million is the max of the current sanction, but that the ACM can always just impose another set of sanctions if they feel Apple hasn't sufficiently fixed the problem. The sanctions can at most be 10% of (dutch) revenue. However, that can double to 20% if Apple re-offends within 5 years. And apparently just paying the fines without any attempt to fix the problem for which you're fined can be considered "Contempt of court", which allows a judge to impose further penalties of increasing severity (not just fines), at least according to this blog post by a dutch lawyer: https://blog.iusmentis.com/2022/02/18/wat-kan-de-acm-doen-dat-wel-indruk-op-apple-maakt/ https://blog.iusmentis.com/2022/02/18/wat-kan-de-acm-doen-da...