Timeline

Regime news and updates

A chronological record of the Isle of Man Data Asset Foundation regime, from concept through legislation, and Cavendish Trust milestones along the way. Updated as the regime develops.

What to watch for next
Secondary regulations under the Foundations (Amendment) Act 2026, prescribing registration particulars, the data governance framework, and accreditation criteria for AAPs
Close of the proposed fee framework consultation on 13 August 2026, and the subsequent Data Asset Register (Fees) Regulations
Award of the Data Asset Register technology platform contract, following tender close on 17 July 2026
Go-live of the Data Asset Register and appointment of the Data Asset Registrar, the operational mechanism through which data assets can be registered
Full operational implementation of the regime, opening registration to eligible foundations once the Register is live
2026
FSA and Department for Enterprise publish formal clarification on the Data Enforcer role
The Isle of Man Financial Services Authority and the Department for Enterprise publish a joint clarification confirming that the Data Enforcer role within the Data Asset Foundations framework does not constitute a new regulated activity under the Island's existing financial services regulatory framework. The Department confirms that the Data Enforcer role is distinct from the pre-existing Enforcer role under the Foundations Act 2011, which is regulated by the FSA as part of its Class 4 (Corporate Services) regulated activities under the Financial Services Act 2008. The clarification resolves a question that had been raised by a number of CSPs and TCSPs, and confirms that any future statutory responsibilities connected to the Data Enforcer role will be established through the relevant Data Asset Foundations legislative and regulatory framework under the Department for Enterprise.
Read the clarification on the FSA website
Data Asset Register technology platform tender closes
The procurement process for the technology platform that will power the Data Asset Register reaches its tender submission deadline. The tender sought a supplier to deliver the digital infrastructure for the Register, covering registration, oversight, compliance monitoring and reporting functions. Award of the contract will determine the technical architecture underlying the world's first statutory register for governed data assets, with the platform expected to be operational as the regime moves toward live implementation later in 2026.
Department for Enterprise publishes proposed fee framework for the Data Asset Register
The Department for Enterprise opens a public consultation on the proposed fee framework for the Data Asset Register, covering registration fees, annual fees, optional services, annual indexation and the proposed approach to reviewing fees as the Register grows. The consultation paper sets out the proposed basis for funding the Register and the fees payable in connection with registered data assets. The consultation closes on 13 August 2026. Responses will be used to inform the Data Asset Register (Fees) Regulations before they are finalised.
View the consultation and respond on Citizen Space
Cavendish Trust launches dedicated DAF services website
Cavendish Trust publishes its dedicated DAF services microsite, now at cavendishdata.com, including a plain-English guide to the regime, an interactive registration journey timeline, the DAF Classification Tool, illustrated use cases across eight sectors, a full regime glossary, and this news feed. The site is designed to serve both prospective clients and those seeking to understand the regime for the first time.
Rick Landman achieves EDMA DCAM V3 Certified Trainer status
Rick Landman is awarded EDMA DCAM V3 Certified Trainer status, recognising his capability to deliver the Data Management Capability Assessment Model (DCAM) Version 3 framework as a qualified trainer. DCAM V3 is the leading industry standard for assessing and maturing enterprise data management capability. The accreditation deepens Cavendish Trust's in-house expertise in the governance frameworks that underpin the DAF regime, and extends the firm's ability to support clients in understanding how DCAM-aligned governance structures map to their DAF obligations.
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Data Asset Register and Registrar consultation closes, Government response published
The Department for Enterprise's consultation on the proposed Data Asset Register and Data Asset Registrar closes on 7 May 2026, having sought views on the proposed architecture, classification framework, access model, and operational approach since it opened in March. The Department has since published a summary of consultation responses, including a separate response from the Information Commissioner's Office. Respondents were broadly supportive of the proposed framework, while highlighting that further detail on classification criteria, costs, and implementation planning will be needed before the Register becomes operational. Feedback will be used to inform the final regulations, supporting guidance, fee approach, and implementation planning for the Register and Registrar.
View the consultation and published response on Citizen Space
Royal Assent granted: the Data Asset Foundations regime becomes law
The Foundations (Amendment) Act 2026 receives Royal Assent, completing the legislative process and bringing into law the world's first statutory framework for recognising and governing data assets. The Isle of Man becomes the first jurisdiction in the world to move from concept to enacted law on data asset governance. With Royal Assent secured, the programme moves into implementation: work continues on the Data Asset Register, the appointment of the Data Asset Registrar, and the secondary regulations required to bring the regime into live operation. Registration of data assets will open once the Register goes live. Cavendish Trust, having supported a pilot through pre-qualification and contributed to the regime's development, is prepared to act as Foundation Council and Registered Agent for client foundations as implementation proceeds.
Bill passes Tynwald: the regime has statutory force
The Foundations (Amendment) Bill 2025 passes Tynwald on 7 April 2026, the final parliamentary step before Royal Assent, establishing the world's first statutory framework formally recognising data as a governed legal asset. Cavendish Trust, having participated in the pilot programme and contributed to working group feedback throughout the development process, is positioned from day one of the regime's statutory life to serve as Registered Agent and Data Enforcer for client foundations.
Read coverage from Manx News
White Paper published: public consultation opens on the Data Asset Register
Digital Isle of Man publishes the DAF White Paper, setting out the proposed architecture for the Data Asset Register and Data Asset Registrar. The Paper introduces the Data Asset Identifier (DAI), the five-group field architecture, the two-axis classification system with four overlay attributes, the three-tier version control framework, and the AI governance position. A public consultation is opened on the proposals ahead of secondary legislation.
View the consultation
Foundations (Amendment) Bill 2025 completes Legislative Council clauses stage
The Bill completes its Clauses Stage in the Legislative Council of Tynwald, progressing toward the final sitting and Royal Assent. The Bill at this stage incorporates the statutory architecture for the Data Asset Register, the Data Asset Registrar, provisional and full registration, and the Data Enforcer oversight role.
Cavendish publishes the DAF Classification Tool
Cavendish Trust publishes the DAF Classification Tool, a free interactive assessment covering suitability screening and asset classification across the twelve-code two-axis matrix. The tool draws directly on the White Paper's classification framework and the Handbook's registration journey logic, and outputs a full classification profile with a downloadable PDF summary.
Cavendish contributes feedback in regime working group sessions
Cavendish Trust takes part in working group sessions contributing to the development of the DAF regime, alongside other industry participants engaged by Digital Isle of Man. The firm's involvement reflects its early and continuing engagement with the regime as it moves from concept toward live operation.
DAF Handbook v1 published
Digital Isle of Man publishes the DAF Handbook v1, setting out the complete operational journey for establishing and running a Data Asset Foundation. The Handbook defines the six-stage journey from Founder preparation (G0) through to first utilisation (G5), the governance accountability model, mandatory artefact checklists, and the RACI matrix across all roles. It is designed to be compatible with future regulations and the data governance framework.
2025
Cavendish begins pre-qualification support for first DAF pilot
Cavendish Trust begins working with its first DAF pilot, supporting a prospective data asset holder through the pre-qualification process and Stage 0 Founder preparation. This is Cavendish's first operational involvement in the end-to-end DAF registration process under live pilot conditions, applying the regime knowledge and working group participation built up over the preceding year.
Rick Landman achieves DCAM v3.1 qualification
Rick Landman, DAF Initiative Lead at Cavendish Trust, completes DCAM v3.1 qualification through the EDM Council, becoming one of the Isle of Man's first DCAM-qualified practitioners. The Data Management Capability Assessment Model v3.1 is the primary data management framework referenced in the DAF accreditation standard, and DCAM qualification provides the technical grounding required for evidence-based assessment work at accreditation.
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Pilot Programme launches: first cohort of foundations begin onboarding
Selected participants in the DAF Pilot Programme are notified and begin onboarding, with the first cohort of pilot foundations starting the pre-DAF preparation process. The pilot is designed to test, refine, and shape the legal, technical, and commercial infrastructure of the regime under real-world conditions ahead of full statutory implementation.
Cavendish Trust becomes an EDM Association member
Cavendish Trust completes EDMA membership and attends the mandatory EDM Association Enforcer training programme held 16 to 18 September 2025. EDM Association membership and completion of the training are requirements for eligibility to act as a Data Enforcer under the DAF regime. This milestone confirms Cavendish's formal participation in the pilot programme and its readiness to take on Enforcer appointments for client foundations.
Pilot Programme applications open: EDMA training scheduled
Digital Isle of Man opens applications for the DAF Pilot Programme, seeking Isle of Man licensed fiduciaries including CSPs, TCSPs, and legal professionals. Mandatory EDMA training for Enforcer eligibility is scheduled for 16 to 18 September 2025. Applications are evaluated against six published criteria and selected CSPs are offered onboarding support ahead of the October 2025 pilot launch.
View the pilot programme details
Digital Isle of Man holds public workshop on the data economy
Digital Isle of Man holds a public workshop titled "Powering the Island's Data Economy," open to all professionals on the Island. The two-part session introduces the DAF initiative, explains the governance model, and explores the commercial opportunities available across legal, fiduciary, technology, and compliance sectors. The workshop marks the beginning of broad industry engagement ahead of the pilot launch.
View the Digital Isle of Man DAF page
Isle of Man and EDM Council announce formal partnership
Digital Isle of Man and the Enterprise Data Management (EDM) Council announce a formal partnership to develop the DAF framework. The partnership gives the Isle of Man access to international expertise, the DCAM and CDMC frameworks, global networks, and tools that support its ambition to lead in trusted data governance. The EDM Council brings the internationally recognised data management standards that form the backbone of the DAF accreditation model.
Read the announcement
DAF concept framework published: Isle of Man begins industry engagement
Digital Isle of Man publishes the initial DAF concept framework and begins structured industry engagement across the Island's legal, fiduciary, technology, and financial services sectors. The initiative positions the Isle of Man as the first jurisdiction to develop a statutory framework recognising data as a legally governable, auditable, shareable, and monetisable asset. Working groups are established to develop governance design, accreditation standards, and operational tooling.
Stay informed as the regime develops. Secondary legislation, the Registrar appointment, accreditation criteria, and the opening of registration will all occur during 2026. To receive updates directly, email info@cavendishtrust.com with "DAF updates" in the subject line and we will keep you informed as milestones are reached.
Sources: Regime entries draw on publicly available information from Digital Isle of Man, IoM Department for Enterprise, Tynwald, the DAF Handbook v1 (January 2026), and the DAF White Paper (March 2026). Cavendish entries reflect Cavendish Trust's own participation in the pilot programme. External links open in a new tab. This feed is maintained by Cavendish Trust and updated as significant developments occur. Last updated July 2026.