We derive a simple model-independent upper bound on the strength of magnetic fields obtained in inflationary and post-inflationary magnetogenesis taking into account the constraints imposed by the condition of weak coupling, back-reaction and Schwinger effect. This bound turns out to be rather low for cosmologically interesting spatial scales. Somewhat higher upper bound is obtained if one assumes that some unknown mechanism suppresses the Schwinger effect in the early universe. Incidentally, we correct our previous estimates for this case.
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