Blog Bio Ressources - Between GDPR compliance and climate imperatives, blockchain is seeking its place in the European energy sector "Part 1" — About the compatibility of blockchain and GDPR

The rise of blockchain is generating increased interest in the sector, where it’s emerging as a push up for decentralization, traceability, and consumer empowerment.

Major actors such as Veolia and EDF are already exploring its potential. Veolia is considering “virtual power plants” based on blockchain, which would allow individuals to participate directly in energy production and distribution.

Several startups are also investing in this technology; Sunchain, a French company, transforms surplus solar self-consumption into cryptocurrency. Internationally, platforms like Power Ledger allow consumers and producers to trade their renewable energy.

But behind this enthusiasm, are hidden two major and anguishing obstacles : the compatibility of blockchain with European data protection law, and the compatibility of its energy footprint with the climate targets imposed on the sector.

In this first part, we will strive at analyzing the compatibility of blockchain and GDPR.

« You shall not use blockchain technology »

Is blockchain technology a « miracle » for the energy sector ?

The question is deliberately provocative, and the term ‟miracle’’ is obviously an exaggeration, but that’s what one might be tempted to think when listing the number of recent projects based on this technology all around the world.

Therefore, it’s not surprising to learn that several blockchain-based projects, aligned with the energy transition, have emerged in Europe too. Some companies dream of democratizing the technology. But even if a famous saying states that, « from dream to reality there’s only one step », it’s important to note that in European reality exists the GDPR, and it may be too big of a step.

As a reminder, the RGPD is a European regulation imposing strict obligations regarding the protection of personal data. The problem is that blockchain relies on characteristics that often conflict with its obligations.

While the GDPR grants the right to erasure, the technology in question guarantees the immutability of data.

Another point of tension : the GDPR requires precise identification of who is responsible for data processing, while blockchain is vague regarding the concept of data controller.

Finally, while the GDPR mandates a specific purpose and a limited data retention period, crypto-assets can lead to excessive data retention and unforeseen uses.

Consequently, many ambitious projects could be excluded from the European Union for non-compliance with the GDPR.

Let’s take smart meters projects as an example: electricity consumption data from such meters could be qualified as personal data if they allow user’s identification and would therefore be subject to the conflicting requirements of the GDPR. Thus, blockchain is potentially a miracle, however, it’s unlikely that water will be turned into wine in Europe… a matter of regulations.

Even so, a coexistence between Blockchain and the GDPR is not inconceivable.

Faith in the coexistence of blockchain technology and GRPD

Blockchain is merely the underlying technology enabling various uses. The CNIL (French Data Protection Authority) specifies that this technology « can be used for asset transfers, as a ledger ensuring traceability, or for launching smart contracts. » Therefore, not all projects using this technology involve the processing of personal data, and thus fall outside the scope of the GDPR.

Furthermore, while doubt remains for projects requiring the processing of personal data, the supervisory authority seems optimistic. It is reasonable to expect that companies will adopt different practices across Europe to comply with the GDPR. Power Ledger, for example, acknowledges that it acts as the data controller for users located in Europe, thereby resolving the issue of identifying the data controller.

Following the lead of the CNIL, the European Data Protection Board adopted guidelines on April 8, 2025, concerning the processing of personal data to support companies in their use of blockchains.

So it appears that blockchain technology has a considerable potential, even within the European Union, where it nevertheless will need to meet the compliance challenge imposed by the GDPR.

However, miracles are not always the work of benefactors. The question therefore inevitably arises: what if, behind the enticing promises of blockchain, lies an environmental tragedy? If so, would European law be able to protect us ?

Tessa Kilo will attempt to give an answer to these head scratching questions in the second part.

Part 2 : https://blog.bio-ressources.com/2025/12/21/between-gdpr-compliance-and-climate-imperatives-blockchain-is-seeking-its-place-in-the-european-energy-sector-part-2-blockchain-as-a-decarbonization-tool-a-major-inconsistency/

Sources :

https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng

https://www.cnil.fr/fr/technologies/blockchain-et-rgpd-quelles-solutions-pour-un-usage-responsable-en-presence-de-donnees-personnelles

https://www.edpb.europa.eu/system/files/2025-04/edpb_guidelines_202502_blockchain_en.pdf

https://www.edpb.europa.eu/system/files/2025-05/edpb-summary-022025-blockchains_en.pdf