The Pilot is a six-month initiative to test and validate the Data Asset Foundation (DAF) framework — a statutory subset of the Isle of Man Foundations Act 2011. A DAF is a new type of foundation designed specifically to hold, steward, manage and derive value from data assets.. Participants will together co-develop best practices, trial the legal and technical infrastructure, and demonstrate the commercial value of treating data as an auditable, monetisable, shareable and governable asset. For example, CSPs will help establish and administer the first pilot DAFs, providing practical insights to shape the full DAF regime due to launch in 2026; service providers will help with drafting the templates, providing assessments and assurance; and data rich companies will provide the datasets to register and onboard onto the data asset register.

Applications are open to Isle of Man–licensed fiduciaries, including CSPs, TCSPs, and legal professionals, with particular emphasis on existing enforcers and foundation administrators. Membership of the EDM Association and attendance at the compulsory EDMA training (16–18 September 2025) are required.

Any data-rich organisations across any industry, including finance, telecoms, healthcare, transport, retail, government or digital platforms, seeking to: 

• Unlock new revenue streams from their data, 
• Enhance trust, auditability, compliance and value creation, 
• Explore data-backed financing and partnerships. 

In addition to any category-specific requirements, all participants must commit to: 

• Nominating at least one dedicated senior programme lead and point of contact; 
• Attending pilot workshops and working groups (expected to be convened fortnightly); 
• Providing structured feedback on legal, operational, and commercial aspects; 
• Supporting the publication of anonymised pilot case studies. 

In addition to the general commitment requirements, the following categories are expected: 

Enforcers:  

• To complete EDMA training (16–18 September 2025) 
• To join the EDM Association (membership fee: $3,500 per organisation) 

Pilot Foundations: 

• To set up a foundation in the Isle of Man; 
• To contribute datasets for registration and testing (scope to be agreed on a case-by-case basis) 

Other Service Providers: 

• To complete specified training as required. 

This is a formal application process. Submissions will be assessed against defined evaluation criteria, with only selected CSPs participating in the Pilot.

Data Asset Foundations recognise datasets as formal assets with registrable ownership, provenance and usage rights. The legal framework focuses on control, governance, responsibilities and rights of use. Data becomes a formally recognised foundation asset when dedicated through a process of registration in the Data Asset Register.

We are awaiting receipt of the final legal advice in relation to data asset ownership and will publish it once finalised.

No, not without explicit legal consent. Data Asset Foundations must comply with the Data Governance Framework, GDPR and data protection laws. Pilot use cases will focus on enterprise datasets, anonymised or aggregated data.

Data Governance will be embedded in the secondary legislation, which will be subject to ongoing reviews and amendments as necessary.

CSPs administer Data Asset Foundations, and each Foundation must have at least one Enforcer (mandatory). Enforcers monitor compliance with the Data Governance Framework and the integrity of the Data Asset Register, and have enhanced statutory powers. Council of Members will be required to engage a Technical Data Steward and a Business Data Steward to manage the data assets on behalf of the data asset foundation.

No, they cannot. Unlike Cayman blockchain foundations, every Data Asset Foundation must have a CSP administrator and an appointed Enforcer.

Yes, it will be compliant with the accounting standards. Financial statements must include, without limitation, the following: 

• disclosure of the basis of valuation for data assets; 
• provision of the qualitative descriptions if valuation cannot be quantified; and 
• a record of any revenue and costs associated with data assets. 
  This aligns with IFRS/GAAP reporting principles. 

No. Enforcers operate independently and are specifically tasked with providing external accountability for the Data Asset Foundations.

Each Data Asset Foundation will be required to appoint one Enforcer.

Enforcers must be a licensed fiduciary or a qualified legal professional and they complete EDMA training (first training is scheduled for 16–18 September 2025).

Enforcers carry fiduciary duties similar to company directors. They are personally liable for wilful misconduct or gross negligence, and this will remain the case in respect of Data Asset Foundations. The new responsibilities will be supported by external partners who will provide assessments, assurance and valuation of data assets.

Regulatory engagement and consultation are ongoing to ensure compliance, fiduciary oversight and alignment with regulations.

Yes. It is expected to generate demand for CSP administration, Enforcer services, auditors, accountants, valuation experts, and legal professionals.

Legal certainty, first-mover advantage, world-class fiduciary oversight, and the ability to trade and account for data assets in a statutory environment.

Yes. The Pilot will test a prototype Data Asset Register and data distribution mechanisms to ensure secure, auditable control.

Participants can apply to administer Data Asset Foundations, provide Enforcer services, or both. Organisations may also refer potential client organisations with use cases for Data Asset Foundations.

Yes, it is for the Enforcers and for Data Stewards. Attendance at the EDM Association Enforcer training from 16–18 September 2025 is a mandatory requirement for eligibility to be an Enforcer. Applications will not be considered without confirmed participation. 

Submissions will be evaluated against six criteria: 

• Capability and Role Fit 
• Impact and Outcomes 
• Commitment to Pilot Requirements 
• Cost and Value-for-Money 
• Long-Term Vision 
• Bonus credit for viable client referrals 

Applicants must complete the online form and provide: 

• Details of your proposed role 
• Organisational experience 
• Anticipated benefits and future commitments 
• Itemised cost proposal 
• Confirmation of EDM Association training attendance 
• Referrals, if applicable 

Referred clients will continue to be managed by the CSP that originally referred them. The Pilot and Digital Isle of Man will not reassign clients without consent. To complete the Pilot Programme as assigned, both the pilot foundation and the CSP must remain committed. In exceptional circumstances, changes to these arrangements may be considered.

Yes. You may include a client referral with a brief description of the use case. If accepted, this client will remain under your management.

End of September 2025.

Applications will be reviewed against the published evaluation criteria. Selected CSPs will be notified and supported through onboarding ahead of the Pilot launch in October 2025.

Training is $700 per enforcer, EDM Association membership is $3500 per CSP or law firm for the first 18 months.

Yes. While CSPs and qualified legal professionals are central to the Pilot, other providers (in law, accounting, valuation, technology or compliance) are invited to join working groups and provide specialist services such as audit, assurance, valuation reports or legal templates. Details of working groups will be provided in due course.

Not all applicants will be selected for the Pilot, but there will still be opportunities to participate in the wider Data Asset Foundation ecosystem: 

• Working Groups: Even if not chosen to administer a Pilot Data Asset Foundation or to be a pilot foundation, your organisation may still join the quarterly working groups, where knowledge, templates, and policy discussions will take place. 
• Ecosystem Services: Legal, audit, accounting, valuation, and compliance providers will also be needed to support Pilot participants, so you may still engage as a specialist service provider. 
• Training: if you attend EDM Association training, this accreditation will still be valid post-Pilot, allowing you to position yourself early as a Data Asset Foundation-ready provider.