DeepSeek is facing a major crackdown in Germany over illegal data transfers to China. Berlin’s data protection watchdog says the AI app sends German users’ data to China without proper safeguards, violating EU privacy laws. Authorities have asked Apple and Google to consider banning the app from their stores.
The issue started when Germany’s data commissioner Meike Kamp said DeepSeek "has not been able to convincingly demonstrate" that German user data is protected in China on par with EU rules.
"DeepSeek has not been able to convincingly demonstrate to my authority that the data of German users is protected in China at a level equivalent to that of the European Union," Germany’s Kamp said, according to a CNBC translation. "Chinese authorities have extensive access rights to personal data within the sphere of influence of Chinese companies."
The launch follows DeepSeek’s rise this year with an AI model built at a fraction of the cost of its competitors, running on cheaper Nvidia chips. Its global chatbot app has millions of downloads but is now under scrutiny across Europe.
If the German case moves forward, experts warn it could spark a full EU ban. Lawyer Matt Holman said a ban would hinge on consensus among EU regulators, but removing the app from Apple’s and Google’s stores would effectively shut it down across Europe.
“It is certainly possible that this incident could lead to an EU-wide ban because the rules that apply in Germany are the same elsewhere in the EU and also in the UK,” Matt Holman, specialist AI and data lawyer at Cripps, told CNBC by email.
“The implications for Deepseek could be, unsurprisingly, quite stark. Access to German citizens’ data will be curtailed. In short order this could expand to the remainder of the EU if other national regulators follow suits meaning EU — and potentially UK — markets will be curtailed if Apple and Google disables the app,” Holman added.
This isn’t DeepSeek’s first Europe run-in. Italian regulators ordered the app blocked there earlier this year. Irish authorities requested data processing info from DeepSeek as well.
The Berlin watchdog said it expects Google and Apple to conduct “timely reviews” to decide whether to ban the app. Both U.S. giants have yet to comment.
CNBC reached out to DeepSeek’s privacy team but hasn’t heard back.
