Soda Labs

EDPB blockchain guidelines

Data protection guidance · Guidelines 02/2025

Regulator or standard-setterEuropePrivacy with disclosure

Confidentiality is workable so long as the regulated firm can identify parties and disclose on demand.

What EDPB blockchain guidelines actually says

The reference text on how European data protection law lands on a ledger, final since 7 July 2026. Its positions are demanding: a public key is personal data whenever it can be associated with an identifiable person, encrypted or hashed on-chain data is not automatically outside GDPR, and unsalted hashes are treated as insufficient on a public chain. On erasure the Board offers architecture rather than a doctrinal exemption. Keep personal data off-chain, delete the off-chain identifiers, or render the on-chain data effectively anonymous, which it concedes is technically demanding. It prefers permissioned designs and treats permissionless ones as needing justification. Zero-knowledge constructions and commitments are acknowledged as mitigations, not exemptions. Guidelines are not binding law, but supervisors follow them.

The instruments that matter

Adopted 7 July 2026
version 2.0, following the draft consulted on between 14 April and 9 June 2025
Public keys as personal data
a wallet address qualifies whenever it can be associated with an identifiable person; unsalted hashes do not escape GDPR on a public chain
Off-chain by default
the Board urges keeping personal data off-chain and expressly prefers permissioned architectures

What this means for confidential transactions

Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.