If the guidelines of the European Data Protection Committee are confirmed in their final version, there will be no use of Bitcoin 100% compliant with European law.
For the specialist, this situation amounts to a de facto ban on bitcoin, without an outright prohibition, due to regulatory conflict. He highlights the absurdity of a scenario in which the technology (immutable blockchain) clashes with the law (right to erasure).
Stachtchenko then details the practical restrictions:
The public key of Bitcoin, qualified as personal data, traps the network in the GDPR.
The impossibility of deleting blocks makes compliance with the right to be forgotten unachievable.
Proposing on-chain anonymization (mixers, zero-knowledge) collides with anti-money laundering rules.
Considering the Regulation on financial transfers (TFR 2023/1113), mixers and “privacy” wallets are considered high risk, with KYC from €1,000. The AMLR (2024/1624) prohibits any solution that favors anonymity.
At the national level, the French law of March 20, 2025 presumes every anonymous transaction to be money laundering.
This double imposition — complying with the GDPR or facing anti-money laundering sanctions — traps the user in a deadlock. Without a legal exit, bitcoin risks becoming de facto illegal in Europe.
The EDPB's public consultation remains open until June 9, 2025. It is crucial that actors in the Bitcoin ecosystem, Web3 companies, and policymakers actively participate in this consultation. Without adaptation of the legal framework, the very use of bitcoin — and more broadly, public blockchains — may become incompatible with European law.
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