It has a maximum, not a minimum: The higher of 4% turnover OR €20m. That means even with 0 revenue, your fine can be up to €20m (It won't, because if you're not making money your small fry to them, but still, the fine can be greater than 0)
20m euro or 4% of revenue, whichever is higher, is the max fine. Up to the individual to say how truly likely it is a small revenueless project could possibly get fined, even with large amounts of malfeasance.
