As the world nears the ten-year anniversary of the EU’s General Data Protection Regulation (GDPR), the landscape of global privacy is more complex, expansive, and consequential than ever. From AI regulation to youth privacy, from international data transfers to enforcement challenges, privacy professionals around the globe are bracing for a pivotal year. The Future of Privacy Forum (FPF) has identified seven key developments expected to shape the privacy landscape in 2025, offering insights into emerging risks, regulatory trends, and global coordination efforts.
1. AI’s Ubiquity Raises Questions of Autonomy and Control
AI systems are now deeply embedded in everyday digital experiences, sparking a wave of regulatory concern over how these technologies affect human autonomy and personal data. With the rise of generative and agentic AI, policymakers are increasingly focusing on protecting individuals’ ability to maintain control over their data and identity. Regulators like the European Data Protection Board (EDPB) are calling for robust rights, including unconditional opt-outs and preemptive objections to data processing for AI. Sensitive data accessed by AI companions—financial records, conversations, routines—are drawing scrutiny, especially when involving bystanders or non-users. Ensuring fair treatment of these “invisible data subjects” will be a growing enforcement priority in 2025.
2. Diverging Speeds of AI Legislation Across Regions
The pace of AI regulation will differ globally. The EU will concentrate on implementing the newly adopted AI Act, a complex framework that demands coordination across multiple enforcement bodies. Asia-Pacific (APAC) jurisdictions like Japan, Singapore, and Australia may slow their regulatory pace, opting to refine existing guidance rather than introduce sweeping legislation. Meanwhile, Latin America is accelerating. Brazil leads the charge toward comprehensive AI legislation, with other nations like Argentina and Chile drafting frameworks influenced by the EU model. Globally, the risk of fragmented rules has prompted calls for harmonization via international standards and regional alignment, particularly around access to AI training data.
3. Cross-Border Data Transfers Return to the Forefront
International data transfers are back on the global privacy agenda—this time intertwined with geopolitical tensions and AI strategy. The continuity of EU–U.S. data flows may be tested, depending on how the U.S. handles Executive Order 14117, which restricts outbound transfers of sensitive American data to “countries of concern.” In Europe, a CJEU ruling allowing damages for unlawful data transfers is expected to spark more litigation. Outside the transatlantic context, regions like APAC are becoming increasingly divided, with countries like Singapore and Japan supporting open data flows, while others such as India and Indonesia favor localization. Alternatives like the Global Cross Border Privacy Rules system may gain prominence as the landscape fragments further.
4. Youth Privacy and Online Safety Take Center Stage
Children’s privacy and online safety are converging into a global policy flashpoint. In APAC, countries are integrating safety provisions into privacy laws, often through age verification mandates—raising fresh concerns about surveillance and proportionality. Australia’s ban on social media for users under 16 is likely to be emulated or closely watched. In the EU, the debate over the Child Sexual Abuse Regulation (CSAR) will dominate headlines, with significant tension between its safety goals and its privacy implications. The broader trend points to a shift toward “child rights by design” approaches, emphasizing children’s well-being, not just compliance.
5. Enforcement and Implementation of Privacy Laws Intensify
With many jurisdictions having passed data protection laws in recent years, 2025 will be a year of operationalization. In APAC, attention turns to implementing India’s DPDPA rules, finalizing Indonesia’s PDP Law regulations, and rolling out changes in Malaysia and Australia. Africa’s regulators will issue sectoral guidance to fill implementation gaps, particularly in finance and education. Latin America’s focus will be on secondary regulations, particularly on AI, children’s data, and subject rights. Even in the EU, which has led global regulatory efforts, attention will shift from rulemaking to enforcement and coherence across intersecting frameworks like the AI Act, the Digital Services Act (DSA), and the Digital Markets Act (DMA).
6. Broader Public Policy Debates Will Influence Privacy Outcomes
Major policy debates—like the balance between innovation and regulation—will influence how privacy laws are enforced or updated. In the EU, shifts in political leadership and priorities may tilt digital policy toward competitiveness, potentially tempering regulatory ambitions. In India, new data-sharing initiatives in AI, healthcare, and agriculture suggest a growing focus on national competitiveness, which could lead to redefinition of non-personal data under India’s privacy laws. Meanwhile, concerns over unchecked government surveillance are expected to rise. In Israel, wartime emergency measures have sparked calls to ensure such powers do not become permanent. In India, constitutional challenges to government exemptions under the DPDPA are likely to reach the Supreme Court.
7. Possible Reopening of the GDPR and Final Thoughts
A once-unthinkable scenario—the reopening of the GDPR—is now increasingly plausible. Enforcement challenges, particularly around AI systems, and overlap with newer EU digital laws may force regulators to reconsider how the GDPR fits into today’s AI-driven world. Whether through procedural reforms or direct legislative revision, the idea is no longer off the table. As 2025 unfolds, privacy professionals should prepare for more than just compliance—they must navigate a dynamic ecosystem shaped by emerging technologies, cross-border tensions, and evolving norms.
Taken together, these trends highlight a privacy environment in flux—shaped by technological change, geopolitical shifts, and growing public concern. Organizations that anticipate and adapt to these changes will be better positioned to manage risk, build trust, and operate responsibly in a data-driven world.
