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The Isle of Man has passed legislation that formally recognises data as a legal asset, creating a new class of licensed structure called Data Asset Foundations (DAFs) that operators can use to put player datasets on balance sheets, use them as loan collateral, or monetise them through licensing agreements.
The Foundations (Amendment) Bill 2025 completed its passage through Tynwald and was developed by Digital Isle of Man in partnership with the EDM Association, a global data management standards body representing more than 350 organisations across six continents. It builds on the existing Isle of Man Foundations Act 2011 and is the first legislation anywhere in the world to establish a statutory framework for treating data as a capital asset.
What a Data Asset Foundation Does
A DAF is a licensed legal structure under Manx law. Businesses place datasets into a DAF governed by a legal charter that defines permitted uses, certified governance standards, and enforceable rules on how the data can be accessed or shared. Once structured within a DAF, the data can be listed on a balance sheet as an intangible asset, used as collateral to secure debt or equity financing, included in M&A valuations, or licensed to third parties including AI developers and research institutions.
Each DAF must embed three core components: a legal charter, a certified governance framework, and enforceable use standards. The certified structure is what allows external parties, including lenders and investors, to assign a verified value to the dataset.
Lyle Wraxall, Chief Executive of Digital Isle of Man, said:
“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.”
Why Gaming Operators Are Particularly Well Placed
iGaming operators are among the most data-rich businesses in any regulated sector. Player behaviour data, loyalty programme records, transaction histories, fraud detection feeds, and odds modelling outputs all represent datasets that have commercial value but have, until now, lacked a formal legal wrapper that lets operators capitalise on that value directly.
The DAF structure changes that in three practical ways. First, operators can use player datasets as collateral for financing, in the same way United Airlines used its frequent flyer programme data to secure a $5bn loan from a bank consortium during the Covid pandemic, a case cited by Digital Isle of Man as an illustration of the model. Second, datasets can be licensed to AI developers or research institutions under terms set by the operator and enforced within the DAF governance charter. Third, the certified data structure could increase M&A valuations for operators holding proprietary datasets, as acquirers gain a legally governed, independently verified view of the data’s worth.
Responsible gambling research is also a cited use case. Operators can structure anonymised player behaviour data within a DAF to share with regulators or academic institutions under defined governance terms, without surrendering control of the underlying dataset.
The Data Sovereignty Angle
For operators currently reliant on US-based cloud infrastructure, DAFs offer a route to reduce exposure to extraterritorial data access. Data held within an Isle of Man DAF sits under Manx jurisdiction, outside the reach of the US CLOUD Act and beyond the direct enforcement scope of both UK and EU data access requests. As regulators across multiple jurisdictions tighten oversight of how operators store and process player data, sovereignty of that data becomes a compliance consideration as much as a commercial one.
Aga Strandskov, Head of Data Strategy at Digital Isle of Man, noted that the island’s legislative agility is part of the pitch:
“All jurisdictions are looking into monetising data but we have the first move to advance, because we are flexible and agile. As an island, we can amend our laws easily, whereas other jurisdictions have complex legal systems where that change will take years.”
Timeline and Pilot
A pilot programme and public consultation are already under way. A full rollout is expected later in 2026. The EDM Association’s pilot pioneer programme ran from September 2025 and is focused on onboarding a cohort of organisations to activate, govern and monetise data assets ahead of full launch. Technology partner opportunities were also opened in parallel.
John Bottega, President of the EDM Association, said:
“Managing data as an asset and defining its financial value are key to driving better business outcomes in our data-driven world. EDM Council’s collaboration with the Isle of Man will help pioneer a trusted, transparent data economy. This partnership sets a new precedent in how data can be responsibly governed and commercially leveraged.”
The Isle of Man has long positioned itself as a progressive tech-friendly jurisdiction, with iGaming operators including major international brands among its licensed base. As other jurisdictions consider similar frameworks, operators that establish DAF structures early could gain an advantage in financing negotiations, M&A discussions, and data partnership agreements.
Enterprise Minister Tim Johnston MHK described the Bill’s passage as “a significant milestone,” with data becoming an increasingly valuable part of global business.
Source: Digital Isle of Man / Tynwald
