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Data Asset Foundations

Donald Edwards 11/05/2026
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What if your data could sit on your balance sheet, or support borrowing? 

For most organisations, that has not been possible with any real certainty. Data has been valuable, but difficult to define, structure or leverage in a meaningful way. 

The Isle of Man is now seeking to change that.  

With the passage of the Foundations (Amendment) Bill 2025 through Tynwald, the Island has introduced a statutory framework that formally recognises data as an asset, capable of being held, governed and commercialised within a legal structure.   

It is a characteristically measured development, but one with potentially wideranging implications. 

 From resource to asset 

Data has long sat at the centre of modern business, yet it has traditionally lacked the clarity required to treat it as a true asset.  

Data Asset Foundations (DAFs) begin to address that gap. 

 Built on the Isle of Man’s foundations regime, they allow organisations to place data within a defined legal vehicle, apply governance rules, and treat it as a recognised capital asset. 

 In practical terms, data can now be structured, ringfenced, controlled and managed with clear ownership and purpose. 

 A familiar concept, applied differently 

From a fiduciary perspective, the underlying approach is familiar.  

The Isle of Man has long used companies, trusts and foundations to hold assets and separate ownership from control. A DAF extends that thinking to data.  

It provides a legal wrapper through which data can be governed independently, with defined rules around access, usage and value. 

 For businesses and advisers, this creates immediate advantages: 

  • clarity of ownership and governance 
  • separation from operational risk 
  • structured sharing and collaboration 

 Commercial implications – now including financing 

The real shift comes in how this can be used.  

By recognising data as an asset, it becomes possible to: 

  • support valuations and enterprise value 
  • use data as collateral in financing and borrowing arrangements 
  • enable controlled data sharing without loss of control 
  • develop governance and assurance services around data stewardship 

 This is a meaningful step. Historically, data has held value but has been difficult to leverage within financing structures. The ability to evidence, govern and ringfence that value changes the conversation—particularly for datarich businesses. 

 Governance remains central 

Importantly, the framework is not solely about monetisation.  

Governance, oversight and compliance are embedded within the structure itself, ensuring that data is managed responsibly and in line with international standards.   

This reflects the Isle of Man’s broader positioning: enabling innovation within a trusted and wellregulated environment.

  From framework to execution 

The legislation establishes the foundation – but its success will depend on how it is used in practice.  

As businesses begin to explore the opportunity, there is a growing need for practical structuring advice, governance design, and alignment with existing entities and arrangements. 

 Where Atla adds value 

For clients considering how data fits within their wider structure, whether as part of a corporate group, investment strategy or technology proposition, Data Asset Foundations introduce both opportunity and complexity.  

Atla is working closely with local providers, legal advisers and financing partners to develop practical, tailored solutions for clients, including structures where data can form part of a broader asset and funding strategy. 

 We support clients to: 

  • assess whether a Data Asset Foundation is appropriate 
  • design governance frameworks around data ownership and control 
  • integrate data structures alongside existing arrangements 
  • explore how data may be leveraged, including in financing contexts 

 

If you are considering how data may form part of your asset base, or how it could support future funding or commercial strategy, we would be pleased to discuss how these new structures can be applied in practice. 

 

 Recognition of data as an asset within a Data Asset Foundation does not itself determine accounting treatment or guarantee its use for valuation or financing purposes. This commentary is for general information only and is not legal, regulatory, tax or investment advice 

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