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Policy brief
Enhancing EU legal frameworks for Digital Extended Reality

Policy brief | 28 February 2023

In short

Digital Extended Reality (XR) technologies technologies combine advanced computing systems (hardware and software) that can change how people connect with each other and their surroundings and influence or manipulate human actions through interactions with virtual environments.

This policy brief sets out recommendations based on the regulatory priorities – including privacy and data protection, the regulation of AI and harmful online content, freedom of expression, non-discrimination, and the protection of special categories of persons, especially children – identified in our analysis of EU laws and policies. We address them to EU policymakers and officials involved in the preparation of legislative or policy initiatives related to XR, virtual reality (VR), augmented reality (AR), mixed reality (MR), the metaverse, natural language processing (NLP), privacy and data protection, and AI systems.

To protect and uphold ethical, legal and fundamental rights and sustainability considerations in the development and deployment of XR, TechEthos encourages policy makers to:

  • Promote EU fundamental rights and encourage the adoption of ethics-by-design approaches;
  • Broaden the scope of Article 9 of the General Data Protection Regulation (GDPR) by removing the purpose requirement for biometric data to be classified as special category personal data;
  • Develop appropriate instruments to tackle and regulate harmful online content in XR technologies;
  • Consider specific use cases in the classification of XR technologies under the proposed Artificial Intelligence (AI) Act;
  • Promote the effective enforcement, monitoring and compliance with EU laws related to XR technologies, such as the GDPR, Digital Services Act (DSA), Digital Markets Act (DMA) and the proposed AI Act.

Find out more about each recommendation by downloading the policy brief below.


Julie Vinders, Trilateral Research (TRI), Ben Howkins, TRI.

Date of publication

28 February 2023

Cite this resource

Vinders, J., Howkins, B. (2023). Enhancing EU legal frameworks for Digital Extended Reality. Extract from Deliverable 6.2 for the European Commission. TechEthos Project Deliverable. Available at:


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