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Last month, the European Data Protection Board (EDPB) published quietly guidelines 02/2025 on the processing of personal data via blockchain technologies. Buried in section 63 is a line that shocked the entire web3 pile: “If removal was not taken into account by design, this can remove the entire blockchain.”
That one clause converts GDPR from the world’s privacy gold standard in a kill switch for every permissionless network. Yes, that includes Bitcoin (BTC), Ethereum (ETH) and the hundreds of those dollars trillions per year.
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The reality is worse than it seems, because the removal of each node is the only accurate way to ‘forget’ a transaction. The guideline effectively makes permissionless networks as standard non-compliance. Public consultation will come off on 9 June – after which the text will be hardened in the European enforcement books. After that, the future of Europe was determined.
GDPR has never been written for sabotage breakers
The 2018 GDPR authors assumed that data lives on centrally controlled servers where a single operator can erase it. Fast-forward to modern public block chains; The opposite is true. Block chains are distributed, unchangeable and boundless.
Public chains depend on thousands of independent nodes that jointly guarantee history. Because rewriting a block that would destroy integrity, the ‘right to forget’ of Article 17 Head-first clashes with the function that makes block chains reliable.
Techniques such as salted hashes, zero-knowledge-proof and off-chain Datapointers minimize or cover up already personal information or hardly hides the new design. Instead, it assumes that a single “data manager” can be identified, which is a different idea that decentralization and permissionless network integrity undermine.
Sovereine-cloud ambitions are at risk
For two years, Brussels promised a sovereign cloud – digital autonomy on European conditions. The last policy goals of the committee are explicit. By 2030, three-quarters of the EU companies should be carried out on cloud-edge technology; 10,000 climate -neutral peripheral nodes must be live, and the upcoming cloud and AI Development Act promises the EU goal in triple = “_ blank” riot = “nofollow”> contain approximately 70% of the European cloud market. Members of the European Parliament warn that EU data without an indigenous backbone one summons from the United States will stay away from exposure to offshore.
The only architecture that can break realistically that grip is a decentralized cloud in which infrastructure providers are coordinated by blockchain stimuli, while data remains in European data centers. If the EDPB makes those grandbooks illegal through the design, Brussels will end the dependence it claims.
Section 63 would knead the builders of Europe
By threatening the removal of the entire chain if a single record cannot be deleted, the design injects existential risk into every European Web3 project and Ices every funer venture financing. The biased for permission, ledgers pushes developers back to the centralized Silo’s policy makers say they are resisting.
Labeling of Volunteer Validators “Data Controllers” would saddle hobbyists with liability of the business community, shrink knot participation and weakening of network security. The treatment of every peer-to-peer link as a regulated international transfer risks that spread the worldwide consensus behind the national borders.
Require human transfers for smart contracts breaks composability and undermines everything from decentralized financing to social and governance reporting on chains, which large energy companies have already tested.
A joint call-to-action of the European Crypto Initiative (EUCI) and Web3Privacy now warns that the concept guidelines “The existence of public block chains throughout Europe fundamentally threaten. What more evidence needs to see that the inclusion of this section will knead its own builders?
Privacy-per-Design beats the ban
A cleaner path retains both privacy and decentralization. Destroying a coding key or proven in zero knowledge that the key is irreparable meets the intention of Article 17 without dismantling a ledger. The guidelines must acknowledge cryptographic deletion in addition to physical erases, state that a hash of 32 byte on chain is not personal data and treat validators as processors instead of ‘controllers’.
Brussels has already demonstrated through the markets in Crypto-Assets Regulation that tailor-made rules for frontier Tech can be made without blanket bans. The sentences of the Kill switch stand out, codifying key-dust removal and the clarifying the validatorstatus would tailor the GDPR to the technical reality, while the sovereign-cloud strategy of Europe remains alive.
The public portal closes in less than a month, and unless paragraph 63 has been re -balanced, Europe risks to spend the following decade on paying American hyperscalers to host ‘sovereign’ data. In the meantime, the rest of the world will build on auditable, privacy -retaining rails beyond the reach of Brussels.
Fast up quickly, builders, investors and policy makers now have to affect that commentary, before Europe stands out for its own digital future.
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Kai Wawrinzinek
Kai Wawrinzinek is a co-founder of the Impossible Cloud & Impossible Cloud Network. He is an experienced entrepreneur with a Ph.D. In the law and a proven track record in building successful companies. Kai recognized the need for enterprise-grade solutions in the web3 room and founded Impossible Cloud Network (ICN), a decentralized cloud platform aimed at creating a decentralized alternative to AWS. Before ICN, Kai founded Goodgame Studios, an online game company, and the company grew to more than 1,000 employees and generated more than € 1 billion in income, making it public in 2018 on Nasdaq by an inverted merger.