Let's read the actual document then shall we? It's written in plain enough language for anyone to understand: http://ec.europa.eu/newsroom/just/document.cfm?doc_id=47889 20m is one of the two ceilings (the other being 10m) for fines, and in several paragraphs in the document I linked the principles of discretionality, effectiveness and proportionality are stated. If a regulator tried to levy a $20m fine against a startup for a first offence, there would be a strong case to appeal the ruling at an EU court