The European Union stands at a regulatory crossroads. In 2018, GDPR became the global gold standard for privacy. But in 2025, it risks becoming the hammer that shatters public blockchains — unless we act.
The newly released EDPB Guidelines 02/2025 do not just challenge developers — they fundamentally threaten the existence of public blockchains. The European Data Protection Board explicitly suggests that when deletion of individual data is not possible, the entire blockchain may need to be deleted. This is not a drill. That’s like calling for the deletion of the internet.
You wouldn't delete the internet to enforce privacy. But they are now seriously considering deleting blockchains.
At the European Crypto Initiative (EUCI), we’ve spent years fighting for decentralised digital rights. Today, we’re sounding the alarm: the time to act is now.
The current GDPR framework — and its reform process — is dangerously out of step with decentralised systems:
🔥 The Blockchain Kill Switch: Regulators propose entire blockchain deletion if personal data erasure is impossible.
🚫 Public Chains Under Attack: Guidelines "favour" permissioned blockchains over public, decentralised ones.
⛓️ Identify Your Controller: Blockchains must establish a "data controller," fundamentally clashing with decentralisation.
🌐 Cross-Border Complexity: Globally distributed nodes trigger GDPR transfer headaches.
🤖 Smart Contract Risks: Automated smart contracts may require human intervention and appeal processes, even post-execution.
🕵️ Deletes the Progress, made with Privacy-Enhancing Technologies (PETs): practically ignores the existence of ZKPs and homomorphic encryption as valid tools for compliance.
The EDPB guidelines create existential challenges for projects like Ethereum:
Potential Blockchain Deletion: If even one piece of personal data can't be erased, the whole chain could be targeted.
Push Toward Permissioned Chains: Public chains must justify their existence against a regulator’s default bias.
Persistent Identifiers: Ethereum’s account-based model could be classified as personal data.
Cross-Border Node Problems: Validators worldwide may trigger complex GDPR transfer rules.
Smart Contracts in Danger: Automated smart contracts risk violating GDPR’s automated decision-making provisions.
The European Data Protection Board’s public consultation on the new blockchain guidelines is open until June 30, 2025. Without urgent input, these draft rules could become the enforcement standard, putting public blockchains at existential risk in Europe. We have a narrow window to ensure that privacy-preserving blockchain technology doesn't get regulated out of existence.
We will soon enter a critical feedback window in the legislative timeline and want to prepare in advance. EUCI is coordinating the Web3 community's voice, and we need yours in it. Here's how you can get involved:
Submit Your Use Case or Comment
We are building a GDPR Reform Feedback Repository with real-world examples from builders. If your project uses PETs, ZKPs, or operates without a clear data controller, tell us what needs fixing. Join our Signal group and submit your case: https://signal.group/#CjQKIFytj2mPisij9AdnQA4bQMKLFPAjcQ_ULXRRzkis0WDiEhBeEX4VMx-UT811iE7nSi_C
Meet the Policymakers With Us
EUCI will be meeting members of the European Parliament, national regulators, and Commission staff. We’re bringing your stories with us. Want to present directly or endorse a submission? Reach out. Contact: info@eu.ci
Support and Get Your Name on the EUCI GDPR Submission
We are preparing a joint Web3 community submission to the EDPB. Add your name to show that builders, researchers, and privacy advocates support decentralised solutions. Make your voice heard! Contact: info@eu.ci or through the Signal group.
We don’t fix this now, and we’ll be living in a Europe where public blockchains are treated as legally noncompliant by default — unless retrofitted with centralised chokepoints. That’s not privacy. That’s regression.
In this pivotal moment, Web3Privacy Now and the European Crypto Initiative (EUCI) are joining forces to defend the future of decentralised, privacy-preserving technologies in Europe and beyond. Our collaboration goes beyond this call to action — together, we are working on building a united front to advocate for privacy, decentralisation and innovation. We have the expertise. We have the community. What we need right now is mobilisation. Let’s not allow bureaucracy to erase the future of decentralised, privacy-preserving infrastructure.
For full details, see the EDPB "Guidelines 02/2025 on Processing of Personal Data Through Blockchain Technologies."
Contact the European Crypto Initiative at info@eu.ci for more information or to get involved.
Author: Vyara Savova
Editor: Andreea, PG