Invisible Citizens, Visible Futures: Rethinking Inclusivity in Urban Digital Twins

Urban Digital Twins (UDTs) are fast becoming integral to municipal governance, furnishing planners with dynamic, data-rich environments for scenario testing and public engagement. Yet early evidence indicates that the benefits of UDTs accrue unevenly, reinforcing pre-existing digital and social divides. This article interrogates the twin hypotheses that (i) limited digital skills and (ii) structural access barriers—such as documentation requirements or inaccessible interfaces—systematically exclude already-vulnerable groups from UDTs, conceived as platforms where citizens can participate in the hybrid physical-digital public sphere. Drawing on a multidisciplinary review of European pilot projects, relevant EU regulations (GDPR, Data Governance Act, European Accessibility Act, AI Act) and an intersectional vulnerability framework, we map how these technologies currently privilege a “participatory elite” while marginalising citizens with low digital literacy, persons with disabilities, undocumented migrants, the unhoused and other precarious communities. We then analyse design choices and governance practices—co-design workshops, flexible identity models, accessibility-by-default guidelines and equity audits—that can mitigate exclusion without compromising legal certainty or system security. Our findings reveal a regulatory lacuna: EU hard-law instruments ensure privacy and basic accessibility but impose no affirmative duty on cities to involve marginalised subjects in the modelling loop. We conclude that vulnerability must be treated as an explicit design and governance variable. Embedding participatory obligations, intersectional equity metrics and adaptive identification mechanisms in future EU regulatory frameworks would enable UDTs to illuminate rather than obscure Europe’s invisible citizens, transforming Digital Twins into genuinely democratic urban commons.