Thanks for the input. Could you clarify whether this is based on a specific legal interpretation or general concerns?
Our view is that the European Subnet is not “GDPR compliant by default,” but enables GDPR-aligned architectures, depending on implementation and governance. Would be great to understand your perspective in more detail.
But, from my perspective, a general statement that the European Subnet is “not GDPR compliant” for personal data is too broad.
There are multiple architectural and operational approaches to address GDPR requirements and the regulation itself defines how compliance can be achieved depending on the setup and roles involved.
In that sense, it is less about whether the infrastructure itself is compliant and more about how it is used and implemented.
The same applies to traditional Web2 providers, they are not GDPR compliant by default. You cannot simply say that a provider in Vienna is compliant out of the box.
Compliance requires a combination of technical and organizational measures, as well as application-level design decisions. This includes principles such as data minimization, purpose limitation, and enabling rights like erasure (“right to be forgotten”) if needed.
It also makes a significant difference what type of personal data is being processed, whether it is customer PII, sensitive data such as health information, or simply a name used for logging purposes.
In all cases, a case-by-case assessment is required to determine whether a system, even if operated within the EU, meets GDPR requirements.
That’s why I would be very interested in understanding the specific reasoning or sources behind your statement.