The Isle of Man has passed the Foundations (Amendment) Bill 2025, creating Data Asset Foundations (DAFs), a new legal structure that allows companies to treat data as an asset. For gaming operators, this opens up opportunities to monetise player data, use it as collateral, and strengthen data governance while reducing exposure to foreign data access laws.
A world-first legal framework for data
The Isle of Man has become the first jurisdiction to introduce a statutory framework that formally recognises data as an asset. The bill has successfully completed its passage through Tynwald, establishing a legal structure that enables data to be recognised, governed and managed within a defined framework. Built on the Foundations Act 2011, the legislation creates a new capability for businesses and marks a significant step in the Island’s economic strategy.
The initiative has been developed by Digital Isle of Man as part of a broader effort to support data-led industries and position the Island at the forefront of the global data economy. As data becomes increasingly central to business activity, the framework is designed to provide organisations with a structured and trusted way to manage and use it.
What Data Asset Foundations enable
A Data Asset Foundation is a licensed legal structure designed to hold and manage data within a formal governance framework. Organisations can place datasets into a DAF, define how that data can be used and by whom, and apply enforceable rules through a legal charter and certified governance structure. The model has been developed in partnership with the EDM Association, ensuring alignment with recognised data management standards.
It allows businesses to recognise data as an asset and defines how it can be valued, shared under set conditions, and used in commercial agreements while meeting governance and compliance standards.
Why it matters for gaming operators
The gaming industry is one of the most data-driven sectors, generating large volumes of information across player behaviour, transactions, fraud detection, payments and customer engagement. Until now, much of this data has held clear value but lacked a formal legal mechanism to structure or leverage it as an asset.
The introduction of DAFs changes that position. Operators can now place datasets within a defined legal structure and use them in ways that support monetisation, financing and partnerships, while maintaining clear governance over how the data is accessed and used. It provides a structure for sharing data with regulators or researchers, including in responsible gambling contexts, while keeping ownership and oversight in place.
Economic strategy and industry response
The Isle of Man government has described the legislation as a significant step in its long-term economic development. Tim Johnston MHK, Minister for Enterprise, said: “The successful passage of this legislation is a significant milestone for the Isle of Man and an important step for our economy. Data is becoming an increasingly valuable part of global business, and this framework ensures that the Island is well placed to support organisations operating in that space.”
“As the first jurisdiction to introduce a statutory framework of this kind, this reflects our commitment to building a diverse, forward-looking economy, one that creates new opportunities, supports innovation, and strengthens the Isle of Man’s position as a trusted and well-regulated jurisdiction.”
Lyle Wraxall, Chief Executive of Digital Isle of Man, said: “Through Digital Isle of Man, we have been developing this concept over a number of years, and this legislation now gives it a statutory foundation.”
“The significance of that should not be underestimated. This is not simply about data policy, it is about creating a practical framework that organisations can use to manage, govern and realise the value of their data in a structured way.”
“The work already underway shows this can be applied in practice and is already creating real opportunity for the Island. The Isle of Man has a strong track record of identifying where markets are going and putting the right frameworks in place. This legislation is the next step in that story.”
Aga Strandskov, Head of Data Strategy at Digital Isle of Man, said: “The challenge has never been the availability of data, it has been the lack of a trusted framework to use it with confidence. What this legislation provides is the legal and governance infrastructure that has been missing. It enables data to be governed, controlled and used in a consistent and auditable way, bringing it closer to how other recognised assets are managed.”
“For the Isle of Man, this creates a real opportunity to play a meaningful role in shaping how data is used across the global economy.”
Data sovereignty and control
The framework also deals with data sovereignty. Data within a DAF is governed by Isle of Man law, which defines how it is managed and accessed. This provides clarity on how data is managed and accessed, particularly for gaming operators operating across regions and using cloud infrastructure.
By placing data within this governed legal structure, operators can maintain control over sensitive datasets and manage how they are handled under a defined legal framework.
Implementation and next steps
Following the passage of the legislation, Digital Isle of Man is leading the development of secondary regulations to support the framework. A public consultation is currently open, and a pilot programme launched earlier this year is already demonstrating how Data Asset Foundations can operate in practice. A Data Asset Register is also being developed as part of the rollout, with full implementation expected later in 2026.
Interest from both local and international organisations is continuing to grow as the Isle of Man moves from legislative approval to practical application.
A shift in how data is valued
The Foundations (Amendment) Bill 2025 represents a shift in how data is treated within a legal and commercial context. By creating a formal structure for recognising and managing data as an asset, the Isle of Man has introduced a framework that aligns data more closely with other recognised forms of value.
For gaming operators and investors, the development raises important questions around how data is valued, structured and used in the future, particularly as the industry continues to rely heavily on data-driven operations and decision-making.
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