Oh the law. Good one.

The same law that fined me $1,800 because a posted notice fell off my door in a blizzard? The same law that allowed the judge to uphold the fine by saying "I don't believe you". Bureaucracy sucks, and the second it gets its tentacles on you, no amount of cheek clenching is gonna delay the inevitable.

You mention the law here. Where in the law does it indicate that the DPA can't assign the maximum fine on the first offense even if it is trivial?

Search for the word "proportionate".

Again, you're derailing. I was replying to the claim that no fine lower than 20 million Euros could possibly be imposed.

In the long list of factors to consider when determining the fine, which the DPA will be found to not have given the legally required consideration on appeal of the fine, if you assume a DPA is going to be stupid enough to try.