# Data Asset Register legal status audit

Reference date: 29 October 2026, Asia/Dubai. This is a verification record, not a certification of current Manx law.

**The requested exact legal position remains unresolved.** Parliamentary proceedings establish an announcement of Royal Assent for the Foundations (Amendment) Act 2026. The authenticated enacted text, operative commencement orders and final made data-register regulations have not been obtained. It is therefore not possible from this source set to certify which substantive provisions are in force, whether a pilot can receive statutory registration, or whether provisional or full applications are accepted today.

The evidence points to a register still being implemented. This supports withholding any representation that registration is currently available; it does not prove that no instrument or restricted pilot arrangement exists.

## What is established

| Question | Verified evidence | Limit |
| --- | --- | --- |
| Was there a proposal? | Introduced Bill, amended Bill, explanatory notes and parliamentary stages have been recovered. | A Bill is not the enacted Act. |
| Was enactment announced? | Tynwald Votes and Proceedings PP 2026/0094, p 7, announces Royal Assent for the Foundations (Amendment) Act 2026 at the May sitting. | This is evidence of enactment, not a copy of the Act or its operative provisions. |
| Was commencement deferred? | Clause 2 of the recovered amended Bill reserves substantive commencement to Department for Enterprise orders. The July government fee paper says substantive provisions will commence on appointed dates. | Neither source identifies every order subsequently made. It is unsafe to infer today's section-by-section position from July's statement alone. |
| Were fees final in July? | The government consultation labels them provisional and subject to further work. | They cannot be represented as a current statutory tariff. |
| What was the October operating position? | Chamber's report of its 6 October event with Digital Isle of Man describes platform development, a recruited registrar, a fee framework awaiting final Treasury approval and a Q1 2027 launch target. | An event report is not a commencement order, made regulations or a registrar's acceptance notice. Its statement that secondary regulations are complete does not prove making, approval or commencement. |
| Can a data asset be registered today? | No official acceptance notice, current application procedure, complete operative instrument bundle or completed statutory registration has been verified. | Availability cannot be certified. The prudent research conclusion is that the scheme should not yet be treated as an available statutory registration service. |

Primary sources: [May parliamentary proceedings](https://manx.42.uk/documents/daf-assent-record.pdf), [amended Bill](https://manx.42.uk/documents/bill-amended-by-keys-2026.pdf), [July government fee paper](https://manx.42.uk/documents/dar-fees-consultation-2026.pdf), [October event report](https://manx.42.uk/documents/chamber-post-event-2026-10.pdf).