Zero-Knowledge Proofs for Privacy-Preserving Compliance

🔍Abstract

This paper examines how zero-knowledge proofs (ZKPs) provide a transformative approach to privacy-preserving compliance across various industries, thereby reshaping the legal, technical, and ethical landscape of data governance.

📝 Executive Summary

Zero-knowledge proofs (ZKPs) are rapidly emerging as one of the most consequential cryptographic innovations of the digital era. At their core, ZKPs introduce proof-based compliance; a paradigm shift that reconciles privacy and accountability. They enable individuals and organizations to verify ownership of data while safeguarding its privacy and security. By enabling trust without disclosure, ZKPs allow organizations to validate compliance with frameworks such as Brazil’s General Data Protection Law (LGPD), California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA); China’s Personal Data Protection Law (PDPL), the EU General Data Protection Regulation (EU GDPR), the U.S. Health Insurance Portability and Accountability Act (HIPAA), and other relevant global laws and regulations.  

The implications extend far beyond legal and regulatory checklists. ZKPs shift compliance from access-based reviews, where auditors examine raw datasets, to proof-based models that rely on cryptographic attestations of adherence. This transition has the potential to transform industries where compliance traditionally conflicts with confidentiality. These industries include healthcare, where genomic data can be safeguarded in HIPAA audits. They also include financial services, where ZKPs can achieve anti-money laundering (AML) and know-your-customer (KYC) compliance without revealing identities. In the artificial intelligence (AI) governance arena, ZKPs enable fairness and bias assessments of training datasets without exposing proprietary or sensitive information. They can directly address challenges introduced by the EU AI Act and other emerging AI governance, legal, and regulatory frameworks.

This tension between compliance, data privacy, and data protection can be visualized as a paradox (see Figure 1). Traditional compliance models expand risk by requiring access to sensitive datasets, while ZKP-enabled models demonstrate compliance through proofs alone, reducing exposure.

Figure 1: The Compliance-Privacy Paradox

Figure 1. The Compliance–Privacy Paradox. Compliance frameworks often require access to sensitive data for audits and oversight, while privacy regulations demand minimization of that same data. ZKPs bridge this paradox by enabling trust without disclosure, allowing compliance to be proven without revealing underlying information.

However, ZKPs are not silver bullets. They raise difficult questions about legal and regulatory trust, technical scalability, operational complexity, and the risk of “black-box” compliance. Their adoption will require new governance frameworks, regulatory sandboxes, auditor training, and industry-wide standards. Forward-looking organizations that invest early in ZKP solutions can gain a strategic advantage, shaping both technical standards and policy expectations.

In short, ZKPs represent not only a technical breakthrough but also a paradigm shift in compliance philosophy. They enable organizations to transition from a world where compliance undermines data privacy and data protection to one where it supports and enhances them. This transition can be better understood by contrasting traditional access-based compliance with proof-based compliance enabled by ZKPs. Whereas the former relies on auditors reviewing raw datasets, the latter allows regulators to validate cryptographic proofs. Figure 2 illustrates how this shift reduces risk surfaces while strengthening accountability.

Figure 2: Access-Based to Proof-Based Compliance Workflow

Figure 2. From Access-Based to Proof-Based Compliance. Traditional compliance models require auditors to inspect raw datasets, thereby exposing sensitive information and expanding the risk surface. With ZKPs, compliance transitions to a proof-based model, where regulators validate cryptographic attestations, thereby reducing exposure while maintaining accountability.

 This article examines the technical underpinnings of ZKPs, their sector-specific applications, governance implications, challenges, and emerging innovations. It sets the stage for a deeper analysis of how this technology can shape the future of privacy-preserving compliance. At their core, ZKPs enable trust without disclosure, allowing compliance to be proven without revealing the underlying data. This principle forms the foundation of proof-based compliance, directly addressing the long-standing paradox between regulatory accountability, data privacy, and data protection.

 

💡 Key Insights for Readers

As organizations navigate increasingly complex data privacy and protection requirements, ZKPs emerge not just as a cryptographic tool but as a strategic enabler of compliance transformation. The following insights capture why ZKPs matter now, how they are likely to reshape industries, and where their most significant opportunities and challenges lie:

1.   Adoption will test governance maturity: Technical complexity, questions of scalability, and the need to build regulatory trust remain formidable challenges. The shift will require new assurance models, auditor training, and collaborative sandboxes to bridge the gap between cryptographers and policymakers.

2.   Proof-based compliance is the emerging standard: As auditors and regulators grapple with the risks of handling vast amounts of sensitive data, cryptographic proofs will increasingly replace raw dataset reviews as the benchmark for demonstrating compliance, reshaping how oversight is conducted.

3.   The cross-sector potential is profound: From protecting patient records in healthcare, to safeguarding customer identities in financial services, to enabling fairness audits in AI governance, ZKPs reduce risk surfaces and create compliance pathways that protect both organizational integrity and individual rights.

4.   The opportunity is transformative: Early adopters of ZKPs can not only reduce compliance risks but also help define the governance standards of tomorrow. By embedding proof-based compliance into privacy-by-design (PbD) frameworks, these organizations will influence how regulators, industries, and societies reconcile trust, accountability, and confidentiality in the digital age.

5.   ZKPs resolve the compliance paradox: They allow organizations to demonstrate adherence to complex data privacy and data protection laws and regulations without exposing the very personal or sensitive information they are legally obligated to safeguard. They align compliance with data privacy and protection rather than setting them at odds.

Taken together, these insights reveal that ZKPs are not a marginal innovation, but a paradigm shift in compliance philosophy. To understand how this plays out in practice, it is necessary to examine the legal and regulatory paradox that ZKPs aim to resolve. We must address the tension between demonstrating compliance and safeguarding data privacy and data protection.

🧭Introduction

Across the global legal and regulatory landscape, data privacy and data protection obligations are intensifying. Laws and regulations, such as the EU GDPR, LGPD, PIPL, and U.S. sector-specific laws like HIPAA, emphasize accountability, demonstrable compliance, and transparency. However, compliance creates a paradox. Organizations must often prove their practices by exposing the very data they are required to protect.

For example, audits may require access to entire datasets, international data transfers may necessitate the disclosure of sensitive records, and AI fairness assessments often involve the disclosure of raw training data. Each of these processes can unintentionally expand the risk surface, increasing the likelihood of data leakage or misuse. ZKPs present a compelling solution to this problem.

By enabling one party to mathematically prove compliance or validity without revealing the underlying information, ZKPs reduce exposure while preserving consumer privacy and regulatory trust (Chaudhary, 2025; Marshall, 2025). This technology, already deployed in blockchain ecosystems, is now poised to reshape compliance, data privacy and protection, and AI governance across industries.

📖 Key Terms

Understanding ZKPs requires familiarity with both their cryptographic underpinnings and the governance frameworks in which they operate. While there are multiple types of zero-knowledge proofs, three variants dominate current discussions: zk-SNARKs, zk-STARKs, and Non-Interactive Zero-Knowledge Proofs (NIZKs). Each offers trade-offs in efficiency, scalability, and resilience against future quantum threats. Table 1 compares these variants across their technical and practical dimensions, highlighting the context in which each is most applicable.

Table 1: Comparison of Zero-Knowledge Proof Variants

Variant	Efficiency	Scalability	Common Use Cases	Post-Quantum Security
zk-SNARKs	High efficiency; compact proofs	Moderate (requires trusted setup)	Blockchain privacy (e.g., Zcash), private transactions	Vulnerable to quantum attacks
zk-STARKs	Less efficient than SNARKs, larger proofs	High (transparent, no trusted setup)	Scalable blockchain solutions, enterprise compliance	Considered post-quantum secure
NIZKs	Very efficient (single message from prover to verifier)	Scale in specific contexts	Authentication, cross-border compliance checks	Dependent on the underlying cryptosystem; it is not inherently quantum-resistant

Source Note: Adapted from Lavin et al. (2024), Chainlink (2023, 2024), and IBM (2025).

These technical variants operate within broader governance frameworks that define how privacy is designed and enforced. To understand how ZKPs align with legal and regulatory expectations, Table 2 summarizes four related frameworks: Privacy by Design (PbD), Data Protection by Design (DPbD), Privacy by Default (PbDefault), and Data Protection by Default (DPbDefault). It also highlights their origins, principles, and codification under law and regulation.

Table 2: Governance Frameworks for Privacy and Data Protection

Framework	Originator	Principles	Regulatory Codification
PbD (Privacy by Design)	Dr. Ann Cavoukian (1990s)	Seven principles (e.g., proactive, privacy as default, user-centric)	Referenced globally; indirectly supported in GDPR
DPbD (Data Protection by Design)	EU GDPR, Art. 25(1)	Technical and organizational measures at the design stage (e.g., minimization, encryption, access control)	Legally binding under GDPR
PbDefault (Privacy by Default)	Cavoukian (1990s, part of PbD)	Systems/services default to privacy-protective settings; the user must opt in to share more	Conceptual, non-binding
DPbDefault (Data Protection by Default)	EU GDPR, Art. 25(2)	By default, only necessary personal data is processed (scope, amount, storage, accessibility)	Explicitly binding under the EU GDPR.

Source Note: Adapted from Cavoukian (2010), Intersoft Consulting (2025a), and EU GDPR Article 25.

While Table 2 contrasts traditional and proof-based compliance, it is also essential to recognize that ZKPs are not the only privacy-preserving mechanisms shaping this landscape. They operate in conjunction with other privacy-enhancing technologies that reinforce compliance and trust.

Privacy-enhancing technologies (PETs) such as differential privacy, homomorphic encryption, post-quantum cryptography, and zero-knowledge proofs of location extend the privacy-preserving toolkit beyond ZKPs. These technologies complement proof-based compliance by enabling organizations to anonymize data, process it securely, and future-proof against quantum risks, while meeting location-based regulatory requirements without exposing sensitive information. Table 3 highlights several of these complementary approaches and their relevance to regulatory obligations.

Table 3: Complementary Privacy-Enhancing Technologies

Technology	Description	Relevance to Compliance
Differential Privacy	Adds mathematical “noise” to datasets, enabling statistical analysis without re-identifying individuals.	Supports anonymization in audits, AI fairness, and EU GDPR compliance (Art. 5, data minimization/Intersoft Consulting, 2025c).
Homomorphic Encryption	Allows computation on encrypted data without decryption.	Enables regulators to validate outcomes without accessing raw datasets (e.g., finance, healthcare).
Post-Quantum Cryptography	Algorithms designed to resist attacks from quantum computers.	Ensures long-term sustainability of ZKP systems in compliance reporting.
Zero-Knowledge Proof of Location(ZK-PoL)	Proves a location-based condition (e.g., car within a subsidy zone) without revealing exact coordinates.	Applicable to transport, electric vehicle subsidies, and vehicle taxation compliance.

Source Note: Adapted from Dwork & Roth (2014), IBM (2025), Lavin et al. (2024), and Bogdanov et al. (2025).

Together, these cryptographic variants, governance frameworks, and complementary PETs show that ZKPs are part of a broader ecosystem of tools and principles. With these foundations established, the discussion now turns to the central challenge ZKPs are designed to resolve: the compliance–privacy paradox, where demonstrating accountability often conflicts with safeguarding sensitive data.

⚖️ The Compliance – Privacy Paradox

In today’s legal and regulatory landscape, organizations face an uncomfortable dilemma: demonstrating compliance often requires revealing the very data they are meant to protect. Traditional audits, international data transfers, and AI fairness assessments frequently demand direct access to raw datasets. Auditors may request employee records to confirm retention limits, regulators may examine sensitive financial transactions for AML checks, and AI oversight bodies may require the review of training datasets to assess fairness.

This creates a paradox at the heart of modern governance: to prove that data privacy and data protection laws and regulations are being upheld, organizations must sometimes undermine data privacy and data protection. The act of demonstrating compliance can expand the hazardous surfaces that laws and regulations, such as the CCPA, EU GDPR, and HIPAA, were designed to reduce. Sensitive data that would otherwise remain protected is circulated among auditors, regulators, and third parties, increasing the likelihood of leaks, breaches, or misuse.

To clarify this dilemma, Figure 3 illustrates the compliance–privacy paradox through two contrasting workflows. The left side shows how traditional compliance expands risk by requiring disclosure. In contrast, the right side shows how ZKP-enabled compliance minimizes risk by replacing data access with proof-based assurance.

Figure 3: The Compliance–Privacy Paradox Workflow

Source Note: Adapted from Chaudhary (2025), Marshall (2025), and Shoemaker (2025), with the author’s synthesis.

ZKPs provide a radical alternative to this broken model. As a PET, ZKPs can allow individuals and organizations to verify their knowledge or ownership of data without exposing or revealing it (Shoemaker, 2025). Instead of handing over sensitive datasets, organizations can present cryptographic attestations that confirm compliance with specific rules. For example, this includes ensuring that only authorized users access medical records, that customer identities are screened against sanctions lists, or that an AI system meets fairness thresholds. Crucially, these proofs reveal nothing beyond the fact of compliance itself.

By shifting from access-based compliance to proof-based compliance, ZKPs not only close a technical loophole but also enhance the system's security. They reshape the very philosophy of oversight. They enable auditors, regulators, and stakeholders to demand accountability. They do not require compromising confidentiality, thereby balancing transparency with the need for discretion in ways that traditional audits cannot.

The implications are profound: if widely adopted, ZKPs could move compliance away from being a process that inadvertently erodes trust toward one that builds it. In this light, ZKPs are not simply a clever cryptographic tool. They are a blueprint for reconciling two forces that have long been in tension: the duty to prove accountability and the obligation to protect privacy.

This shift sets the stage for a more in-depth examination of how ZKPs can actively facilitate compliance across various industries and regulatory domains. From healthcare to finance and from cross-border transfers to AI governance, the move toward proof-based verification represents more than a technological evolution. It reflects a fundamental rethinking of how compliance itself can be achieved. In the following section, we examine how ZKPs function as a compliance enabler, translating cryptographic theory into practical governance solutions.

🔑 ZKPs as a Compliance Enabler

ZKPs are versatile tools whose relevance cuts across industries and regulatory contexts. While their applications vary, they consistently support the same fundamental objective: proving compliance without disclosing sensitive information (Truvera, 2025). ZKPs enable compliance by replacing disclosure-heavy processes with cryptographic assurance. Table 4 compares how audits and regulatory reviews, as well as cross-border data transfers, shift from traditional data access to proof-based models, reducing risk while maintaining accountability.

Table 4: ZKPs as a Compliance Enabler Across Core Domains

Domain	Traditional Requirement	Risk	ZKP-Enabled Process	Benefit
Audits & Regulatory Reviews	Auditors require access to entire datasets to verify lawful processing, consent, or retention limits.	Disclosure of sensitive data to third parties; increased risk of leaks, breaches, or misuse.	Provide cryptographic proof that demonstrates compliance with retention and consent obligations while protecting sensitive datasets.	Minimizes exposure, preserves privacy, and maintains regulatory accountability.
Cross-Border Data Transfers	Regulators demand sensitive records to confirm compliance with adequacy decisions, BCRs. SCCs, or other acceptable safeguards.	Sensitive data must cross jurisdictions, raising risks of interception, unauthorized access, or legal conflict.	Generate ZKPs proving that transfers comply with EU GDPR Art. 46 safeguards without revealing underlying data.	Supports lawful international transfers while protecting confidentiality and reducing risk.

Source: Adapted from Lavin et al. (2024), Intersoft Consulting (2025b), and Chaudhary (2025), with the author’s synthesis.

These examples illustrate how ZKPs transform core compliance functions by reducing risk, preserving confidentiality, and maintaining accountability. With this foundation in place, we can now examine how ZKPs extend into sector-specific applications where compliance requirements are even more stringent.

🌐Sector-Specific Compliance

Beyond core compliance domains, ZKPs are being piloted in sensitive industries where disclosure risks are particularly high. These applications demonstrate how ZKPs enable organizations to meet their legal and regulatory obligations while minimizing data exposure. Sector-specific compliance obligations frequently require the handling of highly sensitive data, creating atension between regulatory oversight and data protection. ZKPs are emerging to resolve this tension by proving compliance without disclosing sensitive information. Table 5 compares how ZKPs can transform compliance processes in various industries, including automobile manufacturing, digital identity, finance, and healthcare, highlighting the risks associated with traditional approaches and the benefits of ZKP-enabled verification.

Table 5: Comparison of Traditional vs ZKP-Enabled Compliance in Sector-Specific Domains

Sector	Traditional Requirement	Risk	ZKP-Enabled Process	Benefit
Automobile Manufacturing	Drivers disclose trip histories or detailed vehicle data to prove eligibility for subsidies or tax schemes.	Exposure of personal driving data; increased administrative overhead.	ZKPs verify that a vehicle qualifies (e.g., within subsidy zone) without revealing complete trip histories.	Protects driver privacy while reducing compliance burden and ensuring eligibility (Bogdanov et al., 2025).
Digital Identity	Users present full identity credentials (passport, DOB, address) to verify eligibility.	Oversharing of personal data; risk of breaches and identity theft.	ZKPs verify only the required attributes (e.g., age 18+, residency, citizenship) without disclosing unrelated details.	Enables selective disclosure; supports EU Digital Identity Wallet and similar initiatives (European Commission, 2025; Privado.iD, 2025; Ridley, 2025).
Finance	Banks and fintechs collect and store complete AML/KYC documentation.	Risk of leaks, misuse, and liability from large data repositories.	ZKPs confirm AML/KYC compliance (e.g., income threshold, sanctions checks) without exposing full documents.	Preserves confidentiality while meeting regulatory requirements (Solomka & Lyubinskyi, 2025).
Healthcare	Hospitals disclose patient records or datasets during audits and research approvals.	Breaches of patient confidentiality; regulatory penalties.	ZKPs provide HIPAA-compliant access control or anonymization without exposing raw data.	Strengthens HIPAA compliance and research integrity while safeguarding patient privacy (Lavin et al., 2024; Marshall, 2025).

Source Note: Adapted from Bogdanov et al. (2025), European Commission (2025), Privado.iD (2025), Ridley (2025), Solomka & Lyubinskyi (2025), Lavin et al. (2024), and Marshall (2025), with the author’s synthesis.

By addressing these core domains, ZKPs show how proof-based compliance can replace disclosure-heavy processes with privacy-preserving assurance. This foundation paves the way for their application in broader sector-specific contexts such as healthcare, finance, and digital identity.

🏛️ Governance Implications

Auditors validate compliance through cryptographic attestations rather than reviewing raw datasets. By embedding privacy into the very fabric of compliance reporting, ZKPs advance the spirit of PbD while demanding new models of legal and regulatory trust, auditor assurance, and organizational accountability.

1.   For auditors, ZKPs shift the role of assurance from reviewing records to validating cryptographic attestations. This transition requires new tools, new training, and potentially new certification frameworks. Traditional audit firms will need to incorporate cryptographic expertise into their teams, and new assurance models may emerge around “proof audits” in much the same way cybersecurity has given rise to penetration testing and SOC reporting.

2.   For organizations, ZKPs highlight the need to invest in infrastructure that supports proof-based compliance workflows. Embedding these systems into day-to-day operations may initially appear costly or complex. However, the long-term benefits of reduced risk, greater regulatory confidence, and enhanced reputational trust make ZKPs a strategic asset rather than a narrow technical control.

3.   For regulators, ZKPs present both a promise and a challenge. On one hand, they enable auditing without exposure, drastically reducing the risks of secondary data breaches caused by compliance processes themselves. On the other hand, regulators must establish clear standards for what constitutes a valid proof, develop methods to independently verify proofs, and determine how ZKPs align with existing obligations under global AI governance, data privacy, and data protection laws and regulations. Without such standards, ZKPs risk being seen as “black-box compliance” that undermines transparency rather than strengthening it.

Successfully integrating ZKPs into compliance is not only a technical task but also a governance challenge. Different stakeholders (i.e., auditors, organizations, policymakers, regulators, etc.) must each adapt their practices to ensure that proof-based compliance is trustworthy, transparent, and scalable. Table 6 summarizes their respective roles and responsibilities, highlighting the standards required, the tools and training needed, and the challenges that must be addressed.

Table 6: Roles and Responsibilities for ZKP-Enabled Compliance Governance

Category	Regulators	Auditors	Organizations	Policymakers
Challenges	Reluctance to trust proofs without traditional evidence; risk of “black-box” perception.	Lack of established proof audit methodologies.	High implementation costs; technical complexity.	Balancing innovation incentives with oversight, ensuring equitable access.
Standards Needed	Define what constitutes a valid ZKP proof; align with GDPR, AI Act, HIPAA, etc.	Develop audit frameworks that incorporate cryptographic attestations.	Adopt internal compliance standards aligned with regulatory expectations.	Establish legal recognition of proof-based compliance; promote interoperability.
Tools	Verification mechanisms to test ZKP validity.	Audit platforms capable of validating proofs without requiring access to raw data.	Infrastructure for generating and managing ZKPs.	National/international registries and certification programs for ZKP tools.
Training	Educate regulators on interpreting cryptographic assurance.	Train auditors in proof validation and cryptographic literacy.	Upskill compliance officers and IT teams to manage ZKP workflows.	Invest in awareness programs and capacity-building initiatives.

Source Note: Adapted from Lavin et al. (2024), Intersoft Consulting (2025b), Marshall (2025), and Chaudhary (2025), with the author’s synthesis.

Taken together, these roles and responsibilities demonstrate that the shift to proof-based compliance will require coordinated adaptation across all governance stakeholders. This sets the stage for considering the broader governance implications of ZKPs.

The broader governance implications are profound: ZKPs offer the opportunity to elevate compliance from a box-ticking exercise to a trust-building mechanism. If adopted responsibly, they could transform compliance from a process that sometimes erodes confidence into one that consistently reinforces it.

However, governance adaptation is only one part of the story. To fully realize the potential of ZKPs, organizations and regulators must also address the practical challenges of adoption, including scalability, complexity, and cultural resistance. The following section addresses these limitations, examining how the promise of proof-based compliance must be balanced against the realities of implementation.

🌍 Real-World Applications

ZKPs are not limited to theoretical cryptography or niche blockchain applications. They are already shaping real-world applications across industries where compliance, data privacy, and data protection must coexist. These examples demonstrate how proof-based compliance can transform regulatory oversight, mitigate risk exposure, and enhance trust.

To better illustrate how ZKPs are already being applied in practice, Table 7 compares their use across several industries. It contrasts traditional compliance requirements with ZKP-enabled processes, demonstrating how proof-based approaches mitigate risks while maintaining accountability in various domains, including AI governance and supply chain compliance.

Table 7: Real-World Applications of ZKPs

Domain	Traditional Requirement	ZKP-Enabled Process	Compliance Relevance
AI Governance	Auditors require access to raw training data and models to verify fairness, transparency, and the absence of bias.	ZKPs prove models meet fairness/non-discrimination thresholds or that training data was anonymized without exposing datasets or algorithms.	Aligns with EU GDPR Art. 5 (data minimization) and EU AI Act oversight.
Digital Identity	Users must present full identity credentials (e.g., passport, DOB, address).	ZKPs confirm only necessary attributes such as age, residency, or nationality without disclosing extraneous details.	Supports EU Digital Identity Wallet and regulatory mandates for age/ID checks (European Commission, 2025; Privado.iD, 2025; Ridley, 2025).
Financial Services	Banks/fintechs collect and store complete AML and KYC documentation.	ZKPs prove AML/KYC compliance (e.g., sanctions screening, income thresholds) without revealing identities or complete histories.	Reduces data breach risks while satisfying AML/KYC regulations.
Government & Public Services	Citizens must reveal full identity details to vote, claim benefits, or cross borders.	ZKPs allow proofs of eligibility (e.g., voting status, visa validity) without exposing unrelated personal data.	Enhances trust in e-voting, border security, and benefits verification (Kraavi & Willemson, 2025).
Healthcare	Hospitals disclose records for audits, trials, or research approvals.	ZKPs demonstrate HIPAA-compliant access controls or anonymization without revealing medical/genomic data.	Strengthens HIPAA compliance and clinical research integrity.
Supply Chain & ESG Compliance	Companies must disclose sensitive supplier data to prove ethical or environmental compliance.	ZKPs verify provenance, sourcing, and carbon accounting without exposing trade secrets.	Supports ESG and sustainability regulations (Malik et al., 2021).

Source: Adapted from European Commission (2025), Privado.iD (2025), Ridley (2025), Kraavi & Willemson (2025), Malik et al. (2021), and Lavin et al. (2024), with the author’s synthesis.

These applications highlight that ZKPs are not a niche technology but a cross-sector enabler of privacy-preserving compliance. They provide organizations with tools to reduce risk while empowering regulators with verifiable assurances.

While these examples showcase the transformative potential of ZKPs, they also expose a critical reality: adoption is far from simple. Technical complexity, scalability limits, and questions of regulatory trust remain significant barriers. To understand how ZKPs can move from innovation to widespread adoption, it is essential to examine the challenges and limitations that stand in the way.

🚀 Current and Emerging Developments

While several industries already demonstrate practical uses of ZKPs, many initiatives remain in the research or pilot phase. These projects highlight how ZKPs are being tested in critical domains (e.g., digital identity, voting, supply chains, border security, etc.). Together, they illustrate the trajectory of ZKPs from innovation to broader adoption.

Additionally, they are advancing beyond theory into pilots across industry and government. These initiatives highlight how enterprises and public institutions are testing proof-based compliance in diverse contexts. Current and emerging developments in ZKPs span both industry and government domains. To illustrate these efforts, the following two tables summarize selected pilots and initiatives. Table 9 highlights enterprise-led projects across various areas, including age verification, blockchain, digital identity, financial services, and supply chain compliance.

Table 9: Industry Pilots of ZKPs Across Sectors

Sector	Project/En-tity	Use Case	Status	Compliance Relevance
Age Verification & Age-Appropriate Design	AesirX CMP	Website age verification without storing or tracking user data	Production/Commercial	Meets UK/EU youth protection rules while minimizing data exposure (AesirX, 2025).
Google ZKP Libraries	Open-source tools for EU-compliant age assurance	Pilot/Developer Tools	Supports EU Online Safety Act/eIDAS selective disclosure (Stapelberg, 2025).
Privado ID	Proof-of-age credentials (e.g., 18+) without revealing birthdate or ID	Pilot/Commercial	Enables proportionate age assurance under UK and EU codes (Privado.iD, 2025).
Blockchain & Cryptocurrencies	Aztec Protocol	Confidential DeFi transactions with regulatory auditability	Pilot/DeFi	Balances financial privacy with audit needs.
Ethereum Layer-2 (zkEVM, zkSync, StarkNet)	Scalability and privacy in on-chain transactions	Production	Maintains privacy with verifiable compliance (Lavin et al., 2024).
Zcash	Shielded transactions using zk-SNARKs	Production	Proven model of ZKPs in financial privacy (The Investopedia Team, 2024).
ZK-Rollups	Efficient, private blockchain transactions	Pilot/Scaling Solution	Enhances scalability while preserving privacy (Rapid Innovation, 2025).
Digital Identity & Authentication	Polygon ID	Self-sovereign identity with selective disclosure	Production/Pilot	Supports Web3 compliance and enterprise use (Polygon Labs, 2022).
Sovrin	Verifiable credentials with ZKP-based selective disclosure	Production	Enables privacy-preserving KYC and authentication (Sovrin Foundation, 2018).
Truvera (Dock Labs)	Reusable digital ID credentials for IAM	Pilot	Helps enterprises deploy ZKP-based authentication (Dock Labs, 2025).
Financial Services	Concordium	Blockchain with ZKP-based identity layer for AML/KYC	Production	Meets AML/KYC while preserving confidentiality (Concordium, 2023).
ING Bank	ZKRP and ZKSM to prove attributes without disclosing values	Research/Pilot	Potential for KYC/AML and financial eligibility proofs (Morais et al., 2018).
Supply Chain & ESG	IBM Food- Trust	Testing ZKPs in supply chain provenance and ESG compliance	Experimental	Verifies sustainability without exposing supplier data (Malik et al., 2021; Sahai et al., 2020).
PrivChain	ZKPs for provenance and carbon accounting	Research/Pilot	Proves ESG compliance without revealing trade secrets (Malik et al., 2024).

Source Note: Adapted from AesirX (2025), Privado.iD (2025), Stapelberg (2025), Lavin et al. (2024), The Investopedia Team (2024), Rapid Innovation (2025), Polygon Labs (2022), Sovrin Foundation (2018), Dock Labs (2025), Concordium (2023), Morais et al. (2018), Malik et al. (2021, 2024), and Sahai et al. (2020), with the author’s synthesis.

While Table 9 highlights how enterprises and technology providers are piloting ZKPs to meet regulatory and market needs, governments are also experimenting with proof-based systems in areas such as voting, digital identity, and border security. Table 10 summarizes these public-sector pilots, showing how states and international institutions are exploring ZKPs to strengthen trust, privacy, and accountability in governance.

Table 10: Current and Emerging ZKP Pilots

Government/Entity	Use Case	Status	Compliance Relevance
Estonia e-Governance (IVXV)	E-voting with ZKPs to prove vote correctness while protecting ballot secrecy	Prototype/Academic Stage	Supports election integrity and voter anonymity (Kraavi, 2024).
EU Horizon 2020 / EU Digital Identity Wallet	Cross-border eID and authentication with ZKPs for selective disclosure	Pilot/Implementation Phase	Aligns with GDPR and eIDAS 2.0 for privacy-preserving identity verification (European Commission, 2023).
U.S. DHS S&T Directorate	Remote identity validation pilots for secure border and airport checks	Pilot/Demonstration	Balances national security with privacy-preserving proofs; future potential for digital travel credentials (U.S. DHS, 2025).

Source Note: Adapted from Kraavi (2024), European Commission (2023), and U.S. DHS (2025), with the author’s synthesis.

Together, these industries and government initiatives demonstrate that ZKPs are transitioning from conceptual promise to operational pilots. While adoption remains uneven and many projects are still in early stages, the momentum indicates that proof-based compliance is gaining global traction. The following section examines the challenges and limitations that must be addressed before widespread deployment can occur.

⚠️ Challenges and Limitations  

While ZKPs hold immense promises, their widespread adoption faces obstacles that are not only technical but also economic, governance-related, and cultural. The very opacity that gives ZKPs their privacy-preserving power also creates tension, as regulators must learn to trust proofs over direct data inspection. Table 11 summarizes the key challenges, their impact, and potential pathways forward.

Table 11: Challenges and Limitations of ZKPs

Challenge	Description	Impact	Potential Solutions
Economic and Access Barriers	Adoption requires specialized expertise and infrastructure investment. Smaller firms, nonprofits, and public agencies may lack resources.	Creates a two-tiered system where only well-funded organizations can adopt ZKPs.	Encourage open-source solutions; subsidize adoption for smaller organizations; promote shared infrastructure.
Regulatory Trust and Acceptance	Regulators are accustomed to reviewing raw datasets. Moving to proof-based compliance requires cultural and institutional change.	Without explicit endorsement, ZKPs risk being sidelined as “too innovative.”	Develop regulatory sandboxes; create standards for ZKP-based audits; foster dialogue between technologists and regulators.
Risk of Black-Box Compliance	Concealing underlying data raises concerns of opacity and potential misuse.	Regulators may fear “blind trust,” undermining confidence in proofs.	Require audit logs; combine ZKPs with explainability mechanisms; establish oversight frameworks.
Scalability and Performance	Proof generation and verification remain computationally intensive for large datasets and frequent transactions.	Limits use in large-scale auditing or continuous AI fairness checks.	Advance zk-SNARK/zk-STARK efficiency; apply batching/aggregation; explore hardware acceleration.
Technical Complexity	ZKPs rely on advanced mathematics that exceeds the expertise of most compliance teams.	Creates dependence on a handful of experts or vendors, risking centralization.	Provide training; simplify tooling; build user-friendly verification frameworks.

Source: Adapted from Lavin et al. (2024), Avatier (2025), TRUENDO (2024), and Intersoft Consulting (2025b), with the author’s synthesis.

Taken together, these challenges remind us that ZKPs are not a silver bullet. They emphasize the importance of collaboration among technologists, regulators, and industry leaders to ensure that proof-based compliance is trustworthy, scalable, and accessible. Recognizing these limitations should not lead to dismissing ZKPs, but rather to accelerating research, regulatory experimentation, and industry innovation. Encouragingly, many initiatives are already underway to address these barriers.

Recognizing these limitations is not a reason to dismiss ZKPs but rather a call to action. The existence of obstacles underscores the urgency of continued research, regulatory experimentation, and industry innovation. Encouragingly, many initiatives are already underway to address these challenges. To understand how the field is evolving, we now examine the current and emerging developments that indicate the trajectory of ZKP adoption across various industries and jurisdictions.

🎯 Key Takeaways

To ensure that the lessons of this paper are both clear and memorable, Figure 4 summarizes the five key takeaways of ZKP adoption. Each insight reflects how ZKPs can transform compliance, from resolving the compliance–privacy paradox to aligning with principles of PbD.

Figure 4: Five Pillars of Proof-Based Compliance

These five pillars highlight the essential dimensions of ZKP adoption. They range from resolving the compliance–privacy paradox to embedding privacy by design and privacy by default into compliance workflows. The following discussion expands on each pillar in more detail, showing how these insights shape the future of proof-based compliance. The pillars include:

1.   Adoption Challenges Remain: Technical complexity, scalability issues, economic barriers, and regulatory trust must all be addressed before ZKPs can move from pilots to mainstream adoption. These challenges are not insurmountable, but they require active collaboration between technologists, regulators, and industry leaders.

2.   Governance Frameworks Must Adapt: Regulators, auditors, and policymakers will need to update standards, tools, and assurance models to validate cryptographic proofs. Without such adaptation, ZKPs risk being sidelined as unrecognized or insufficient for official compliance purposes.

3.   ZKPs Are Cross-Sector Applicable: Their potential extends far beyond blockchain and finance, reaching into healthcare, supply chains, AI governance, identity management, and government services. Wherever privacy and accountability must be reconciled, ZKPs offer a viable path forward.

4.   ZKPs Must Align with PbD or Similar Frameworks: By embedding privacy protections into compliance workflows from the outset, ZKPs advance the vision articulated by Dr. Ann Cavoukian and later codified in part through the EU GDPR’s Article 25. They demonstrate how privacy can serve as the foundation of compliance rather than its casualty.

5.   ZKPs Resolve the Compliance – Privacy Paradox: ZKPs, namely ZK-Pols, enable organizations to demonstrate compliance with laws and regulations without exposing the highly personal or sensitive data they are required to protect (Bogdanov et al., 2025). This changes compliance from a risk-expanding exercise into a privacy-preserving one.

Taken together, these insights make it clear that ZKPs are not just a tool for better compliance but a catalyst for rethinking the relationship between privacy, accountability, and trust. The question now is how quickly organizations, regulators, and industries can move from concept to widespread implementation. As we reflect on these takeaways, it becomes evident that ZKPs are not merely an incremental innovation but a transformative force in the governance of data and technology.

To close, we must consider what their adoption means for the future. More importantly, we must do so not only for compliance departments and individuals with similar responsibilities. We must also do so for societies grappling with the balance between transparency, accountability, and individual rights.

🔒 Conclusion

ZKPs represent far more than a technical advance in cryptography. They are a paradigm shift in how accountability, data privacy, data protection, and trust intersect. By replacing disclosure with verification, ZKPs transform compliance from a process that often undermines privacy into one that actively protects it. This inversion of the traditional model positions ZKPs as one of the most powerful privacy-preserving tools available to organizations today.

As adoption spreads, ZKPs could become a foundational mechanism for reconciling privacy and compliance across multiple domains. In AI governance, they provide a pathway to conduct fairness, bias, and transparency audits without exposing sensitive training data or proprietary models. In finance, they can prove adherence to AML and KYC rules without revealing customer identities. In healthcare, they enable HIPAA-compliant audits without jeopardizing patient confidentiality. The same logic applies across supply chains, identity systems, and government services. It applies wherever regulators demand proof of accountability; ZKPs can provide it without compromising data integrity.

Nevertheless, the promise of ZKPs comes with a challenge: their potential will only be realized if regulators, auditors, technologists, and organizations are willing to embrace a new compliance paradigm. Proof-based assurance requires not only technical adoption. It also involves

adapting governance to new standards, oversight models, andtrust frameworks. Without these, ZKPs risk remaining pilots and prototypes rather than mainstream compliance tools.

The broader implication is clear: ZKPs invite us to reimagine the role of compliance itself. Instead of being a check-box exercise that increases risk, compliance can evolve into a trust-building mechanism. It can demonstrate accountability, preserve privacy, and strengthen public confidence in digital systems.

As we move deeper into a data-driven era shaped by artificial intelligence, globalization, and heightened regulatory expectations, the organizations that explore ZKPs today will be the ones defining the compliance frameworks of tomorrow. The choice is not whether ZKPs will matter, but how quickly industries and regulators can harness them to create a future where privacy and compliance are not in tension, but in harmony.

❓ Key Questions for Stakeholders

The ZKPs raise profound questions that extend beyond cryptography into governance, accountability, and the very philosophy of compliance. These questions are not easily answered, nor should they be. Their purpose is to provoke deeper reflection and spark dialogue among regulators, policymakers, organizations, and individuals.

1.   For Data Subjects and Civil Society:

·         How can individuals be assured that their rights, which include access, correction, and erasure, remain enforceable in a proof-based compliance world?

·         Will the opacity of ZKPs to non-experts reduce public trust, or will they inspire greater confidence in data protection?

·         How can advocacy groups and civil society organizations evaluate whether ZKPs truly enhance privacy rather than reframe compliance?

·         Should individuals have the right to demand ZKP-based compliance from organizations handling their personal data?

·         How might ZKPs reshape the public’s expectations of transparency, accountability, and trust in digital systems?

2.   For Organizations and Industry Leaders

·         What infrastructure, expertise, and governance processes must organizations build to integrate ZKPs into compliance workflows?

·         How can organizations measure the return on trust that ZKPs deliver beyond cost savings or risk reduction?

·         Should ZKPs be deployed selectively (e.g., for high-risk data) or integrated comprehensively across all compliance domains?

·         How might reliance on ZKPs affect relationships with auditors, customers, and partners who may be unfamiliar with cryptographic assurance?

·         Could the early adoption of ZKPs become a competitive differentiator, signaling more substantial privacy commitments to customers and investors?

3.   For Policymakers and Standards Bodies

·         Should regulatory sandboxes and pilot programs be established to accelerate safe experimentation with ZKPs across industries?

·         How can global standards bodies (e.g., ISO/IEC, NIST, ITU) ensure interoperability of ZKP-based compliance systems across jurisdictions?

·         What role should governments play in funding or incentivizing research into scalable, quantum-resistant ZKP implementations?

·         Should ZKPs be explicitly recognized in legislation as acceptable forms of compliance evidence?

·         How do policymakers ensure that access to ZKP technology is equitable and not limited to resource-rich organizations, creating a “privacy divide”?

4.   For Regulators and Auditors:

·         How can regulatory bodies develop standards for accepting ZKPs in audits without compromising transparency?

·         Should regulators require organizations to provide independent third-party verification of proofs to avoid “black box” compliance?

·         What safeguards are needed to ensure that ZKPs preserve, rather than weaken, accountability and oversight?

·         Could regulatory reliance on ZKPs reduce audit costs and risks, or will it introduce new layers of complexity and dependence on cryptographic experts?

·         How can regulators balance the efficiency of proof-based compliance with the democratic demand for visible transparency?

These questions highlight that ZKPs are not just a technical innovation. They are a catalyst for rethinking the future of compliance and governance. By challenging regulators, organizations, policymakers, and individuals to reconsider what trust and accountability mean in the digital age, ZKPs force us to ask not only how compliance should be proven, but also what values it ultimately serves.

📚 References

1.    AesirX. (2025, August 14). Privacy without surveillance: Age verification done right with zero-knowledge proofs. AesirX. https://aesirx.io/blog/aesirx/privacy-without-surveillance-age-verification-done-right-with-zero-knowledge-proofs

2.    Bodganov, D., Brito, E., Jaakson, A., Laud, P., & Rebane, R.M. (2025, June 20). Zero-knowledge proof-of-location protocols for vehicle subsidies and taxation compliance. arXiv. https://doi.org/10.48550/arXiv.2506.16812

3.    Cavoukian, A. (2010, May). Privacy by design: The seven foundational principles. The Sedona Conference. https://www.thesedonaconference.org/sites/default/files/conference_papers/Recommended%20%5B08b%5D%20Privacy%20By%20Design_Cavoukian.pdf

4.    Chainlink. (2024, July 29). What is zero-knowledge proof? https://chain.link/education/zero-knowledge-proof-zkp

5.    Chainlink. (2023, November 30). Zero-knowledge proof: Applications & use cases. https://chain.link/education-hub/zero-knowledge-proof-use-cases

6.      Chaudhary, A. (2025, June 9). zkFi: Privacy-preserving and regulation-compliant transactions using zero-knowledge proofs. arXiv. https://arxiv.org/abs/2307.00521

7.      Coin Edition. (2025, August 11). Understanding zero-knowledge proofs: A beginner’s guide. https://coinedition.com/understanding-zero-knowledge-proofs-a-beginners-guide/

8.    Concordium. (2025, August 15). ZKPs: The cryptographic backbone for private online age verification. https://www.concordium.com/article/zkps-the-cryptographic-backbone-for-private-online-age-verification

9.      Dwork, C., & Roth, A. (2014, August 11). The algorithmic foundations of differential privacy. Foundations and Trends® in Theoretical Computer Science, 9(3–4), 211–407. https://doi.org/10.1561/0400000042

10. European Commission. (2025). EU Digital Identity Wallet: Architecture and reference framework. https://eu-digital-identity-wallet.github.io/eudi-doc-architecture-and-reference-framework/2.4.0/ 

11. IBM. (2025). What is homomorphic encryption? https://www.ibm.com/think/topics/homomorphic-encryption#:~:text=Fully%20homomorphic%20encryption%20(FHE)%20is,various%20security%20and%20privacy%20risks.

12. Intersoft Consulting. (2025a). Art. 5 GDPR: Principles relating to processing of personal data. https://gdpr-info.eu/art-5-gdpr/

13. Intersoft Consulting. (2025b). Art. 25 GDPR: Data protection by design and by default. https://gdpr-info.eu/art-25-gdpr/

14.  Intersoft Consulting. (2025c). Art. 46 GDPR: Transfers subject to appropriate safeguards. https://gdpr-info.eu/art-46-gdpr/

15.  Kraavi, T., & Willemson, J. (2025, August). Proving vote correctness in the IVXV internet voting system. Nature Scientific Reports. http://dx.doi.org/10.1038/s41598-025-16764-1

16.  Lavin, R., Liu, X., Mohanty, H., Norman, L., Zaarour, G., & Krishnamachari, B. (2024, August 1). A survey on the applications of zero-knowledge proofs. arXiv. https://doi.org/10.48550/arXiv.2408.00243

17. Marshall, M. (2025, July 8). Privacy-preserving authentication: How zero-knowledge proofs are transforming enterprise identity security. Avatier. https://www.avatier.com/blog/privacy-preserving-authentication/

18.  Malik, S., Dedeoglu, V., Kanhere, S., & Jurdak, R. (2021, April 27). PrivChain: Provenance and privacy preservation in blockchain-enabled supply chains. arXiv. https://arxiv.org/abs/2104.13964

19. Morais, E., van Wijk, C., & Koens, T. (2018, October 15). Zero Knowledge Set Membership (ZKSM) [White paper]. ING. https://www.ing.com/MediaEditPage/Zero-Knowledge-Set-Membership-ZKSM-whitepaper.htm

20. Polygon Labs. (2022, March 29). Introducing Polygon ID, zero-knowledge identity for Web3. https://polygon.technology/blog/introducing-polygon-id

21. Privado.iD (2025, January 15). The need for standardized proof of age credentials in the digital age. https://www.privado.id/blog/standardized-proof-of-age-credentials-in-the-digital-age

22. Rapid Innovation. (2025). Top 10 blockchain zero-knowledge proof use cases. https://www.rapidinnovation.io/post/top-10-blockchain-use-cases-of-zero-knowledge-proof

23.  Ridley, J. (2025, July 31). The UK’s new age verification is a privacy nightmare, but it doesn’t need to be. PC Gamer. https://www.pcgamer.com/hardware/the-uks-new-age-verification-is-a-privacy-nightmare-but-it-doesnt-need-to-be/

24. Sahai, S., Singh, N., & Dayama, P. (2020, November 2 - 6). Enabling privacy and traceability in supply chains using blockchain and zero knowledge proofs [Paper presentation]. 2020 IEEE International Conference on Blockchain (Blockchain). Rhodes Island, Greece. https://doi.org/10.1109/Blockchain50366.2020 

25.  Shoemaker, P. (2025, July 10). What are zero-knowledge proofs (ZKP)? Identity.com. https://www.identity.com/zero-knowledge-proofs/

26.  Solomka, I., & Liubinskyy, B. (2025, January). Zero-knowledge proof framework for privacy-preserving financial compliance. Mathematical Modeling and Computing, 12(1), 342-354. https://doi.org/10.23939/mmc2025.01.342

27. Sovrin Foundation. (2018). The Sovrin protocol and token: A technical white paper. Sovrin Foundation. https://sovrin.org/wp-content/uploads/Sovrin-Protocol-and-Token-White-Paper.pdf

28. Stapelberg, A. (2025, July 3). Opening up ‘zero-knowledge proof’ technology to promote privacy in age assurance. Google. https://blog.google/technology/safety-security/opening-up-zero-knowledge-proof-technology-to-promote-privacy-in-age-assurance/

29. The Investopedia Team. (2024, August 2). ZCash: What is it, why it was created, how to mine it. Investopedia. https://www.investopedia.com/terms/z/zcash.asp

30. Truvera. (2025, September 12). Zero-knowledge proofs: A beginner’s guide. Dock Labs. https://www.dock.io/post/zero-knowledge-proofs

31. Truendo. (2024, December 18). The growing adoption of zero-knowledge proofs: Revolutionizing privacy tech. https://www.truendo.com/en/blog/the-growing-adoption-of-zero-knowledge-proofs-revolutionizing-privacy-tech

32. U.S. Department of Homeland Security. (2025, June 25). S&T launches next phase of industry competition to develop revolutionary identity verification tech. Science and Technology. https://www.dhs.gov/science-and-technology/news/2025/06/25/st-launches-next-phase-industry-competition-develop-revolutionary-identity-verification-tech