Data assets around the world

Research date: 30 October 2026. Prepared for the Isle of Man agentic economy research.

What the evidence establishes

China is the closest verified registration comparator. South Korea and Japan are particularly relevant for statutory protection of commercially valuable data. The European Union provides the strongest comparison for registered, independently governed data intermediaries. Vietnam now has an enacted data-economy framework and data-exchange rules. These systems solve different parts of the problem the Isle of Man is addressing.

This is a worldwide search for materially similar arrangements, with detailed treatment of the strongest matches and a jurisdiction ledger below. It is not a certification that every country and every subnational jurisdiction has been exhaustively audited. Coverage is strongest for China, the EU, the UK, the US, India, Japan, Korea, Australia, New Zealand and selected international financial centres. Countries without a verified comparator are not represented as having no relevant law. Translations and summaries below are explanatory; original-language instruments control.

The Manx baseline also remains qualified: Royal Assent was announced for the Foundations (Amendment) Act 2026, but the authenticated enacted text, applicable commencement instruments and final operative regulations have not been recovered in this project. The intended constitutive property effect is evidenced by the amended Bill. An October industry event report targets launch in Q1 2027. That does not establish a registration service open today. See the Manx legal-status audit.

No exact operational foreign equivalent combining a dedicated foundation, constitutive dataset-property registration and recurring independent assurance was verified in this search. This finding does not substantiate a global “first” or “only” claim.

What counts as similar

For each regime, ask six questions:

1. What is protected: raw facts, a processed dataset, access permissions, a database investment, a token, or a person's privacy?
2. Does a register record an asset, an organisation, a transaction, a regulated service provider, or simply an inventory?
3. Does registration create rights, supply rebuttable evidence, or record compliance?
4. Who holds the rights: a producer, a person described by the data, a public authority, an intermediary, or a separate asset-holding entity?
5. Which assurance, valuation, security and governance requirements apply?
6. Can somebody actually apply now, and on what eligibility conditions?

“Data ownership”, “data IP”, “digital asset” and “registered” cannot be treated as interchangeable answers. Nor does registration itself guarantee lawful AI training, accounting recognition, a reliable valuation, a loan, or recognition abroad.

The strongest comparisons

Sources and qualifications for every row follow.

China: registration already exists, including a new national service

National policy and national registration are separate from local data-IP schemes

China's 2022 “Twenty Data Measures” deliberately emphasised separable rights to hold data resources, process and use data, and operate data products. The official explanation says the approach deemphasises ownership and prioritises use. It is a useful warning against translating every Chinese reference to 数据产权 as unrestricted ownership of information. National Development and Reform Commission explanation, 19 December 2022.

The National Data Administration issued the Data Property Rights Registration Work Guidelines (Trial), 国数综政策〔2026〕35号, on 1 July 2026; its publication notice is dated 4 July. The official explanation describes six chapters and 42 articles, voluntary registration, five registration types, and certificates as trusted evidence of rights and contents. This is an issued administrative framework, not an Act of the national legislature. Issuing notice and original attachment, official explanation.

On 11 September 2026, the national registration service entered trial operation. The first listed registration institutions were Beijing International Big Data Exchange, Shanghai Data Exchange and Shenzhen Data Exchange. Applications are handled through registration institutions; the national system aggregates results and provides publication, verification and inquiry. This is evidence of an operating trial service, not merely an announced future platform. National Data Administration launch notice.

The Guidelines' procedure includes application materials establishing identity, lawful acquisition of rights, dataset descriptions and samples; examination; publication and objections; and recording. They provide initial, transfer, change, renewal and cancellation registration. The general registration term is no more than five years. Certificates support transactions, accounting and financing evidence, disputes, and policy applications. They should not be described as indisputable ownership deeds or guaranteed asset valuations. Official municipal republication of the complete Guidelines, especially arts 24–33.

Practical route: identify the relevant authorised registration institution, check its current intake and applicant requirements, document the chain of permissions and restrictions, and apply there. The national portal is linked in the launch notice. Neither access by every overseas applicant nor unconditional registration of personal data is established by that notice.

Accounting is another layer

The Ministry of Finance issued Interim Provisions on Accounting Treatment of Enterprise Data Resources, 财会〔2023〕11号, on 1 August 2023, applicable from 1 January 2024. Qualifying data resources may be accounted for under existing intangible-asset or inventory standards; resources failing recognition criteria are not automatically capitalised. Registration, recognition, valuation and financing remain separate decisions. Official issuing notice, original provisions, Ministry explanation.

Provincial and municipal arrangements

CNIPA's December 2023 designation lists 17 pilot jurisdictions, and its April 2025 acceptance notice confirms all 17 completed that assessment. A July 2026 Shenzhen authority article reports 23 participating provinces/cities, but does not supply the complete updated list. The table therefore names the 17 verified designated jurisdictions; it does not mislabel that historical list as the full October 2026 network. Designation, assessment, 2026 expansion report.

Shanghai's authority reported 1,097 certificates issued from 1,518 applications by the end of February 2026, and RMB345 million of pledge financing across 16 enterprises. These are authority-reported programme statistics, not independently audited returns or a global ranking. They nevertheless establish an important competitive point: China already has recorded registrations and reported financing activity. Shanghai IP authority, 3 March 2026.

Lesson for the Island: distinguish the asset, the underlying permissions and the legal effect of a certificate. Publish real completion, objection, renewal and financing evidence. Do not compete through an unsupported claim that other jurisdictions have never registered data.

South Korea: “data assets” are already expressly recognised in legislation

The Framework Act on Promotion of Data Industry and Data Utilization, Act No 18475 of 19 October 2021, expressly protects data assets in article 12: economically valuable data produced through substantial human or material investment and effort. It prohibits specified unfair appropriation, with remedies connected to the unfair-competition legislation. Article 14 supports valuation methodologies and designated valuation institutions; article 16 requires reporting by transaction and analytics providers; article 20 addresses quality certification. The official English text includes 2025 amendments. This is substantial statutory recognition of valuable data, but not a general foundation-based registry creating exclusive title in all datasets. Official statute, arts 7, 12, 14, 16 and 20.

Separately, Korea licenses MyData businesses under the Credit Information Use and Protection Act. The regulator granted the first 28 full licences on 27 January 2021. That regime concerns personal financial-data management, not ownership of a registered commercial dataset. Financial Services Commission announcement.

Practical relevance: Korea is a close comparator for assurance, valuation and remedies; a weaker comparator for constitutive registration. Protection arises from qualifying facts and unlawful conduct, rather than formation of a special foundation.

Japan: protected shared datasets and information banks

Japan's Unfair Competition Prevention Act protects qualifying shared data with limited access against specified wrongful acquisition, disclosure and use. The regime is particularly relevant to commercial datasets shared with authorised customers without necessarily being trade secrets. It does not create a registration requirement or property title over every constituent fact. Consult the current definition and exclusions, rather than treating all electronic information as protected. Official bilingual Act, METI data guidance.

Japan also has an information-bank certification programme for trusted personal-data management. The certification operator is the Japan IT Federation's information-bank promotion committee. This is an organisational certification comparison, not evidence of an enacted data-asset title register. Programme operator, METI legislation and June 2026 guidance index.

Lesson: the Island needs a clear commercial answer for customers who already have contractual and unfair-competition protection: what additional enforceable protection and transaction convenience does registration purchase?

Vietnam: an enacted data market framework

The Law on Data, No 60/2024/QH15, was adopted 30 November 2024 and took effect 1 July 2025. It regulates digital data, data governance and use, the National Data Centre, and data products and services. It recognises data owners and managers and provides for intermediaries and exchanges. It should be read with its implementing instruments and privacy restrictions; its enactment is not evidence that any foreign applicant can register any dataset. Government law record and original attachment, official legislative text.

Decree 169/2025/ND-CP, dated 30 June 2025, covers data science, innovation, products and services. Decree 314/2026/ND-CP, issued 8 August 2026, regulates data exchanges and took effect 25 September 2026. The latter's official explanation addresses ownership, exploitation and use rights, transparent listings and transactions, and protection of lawful interests. An effective decree is distinct from proof that every envisaged exchange service is accepting applicants. Official Gazette: Decree 169, government record: Decree 314, government explanation.

Lesson: Vietnam is a meaningful legislative competitor for an organised data economy. It is not established here as a Manx-style foundation/title system. Further diligence should examine the actual operator, licensing conditions and transaction restrictions before suggesting a Vietnamese registration route.

European Union: registered stewardship, rather than registered dataset ownership

The Data Governance Act, Regulation (EU) 2022/868, applies from 24 September 2023. Chapter III regulates data intermediation services; Chapter IV provides voluntary recognition of data-altruism organisations. Intermediaries facilitate sharing under neutrality and legal-separation requirements. Recognised altruism organisations have a not-for-profit character and safeguards for voluntary public-interest sharing. These registers concern organisations, not title to each dataset. Official Act, Commission explanation.

The Commission's intermediary register, updated 13 October 2026, contains 39 listed organisations across ten countries when counted from the page's individual provider links. This is a dated page count, not a measure of market share or all active data-sharing services. The actual entries demonstrate operational notification arrangements. EU intermediary register.

The table derives from the single official register; it does not independently certify each provider's current trading activity. The separate recognised data-altruism register is the appropriate reference for public-interest stewardship.

The same directly applicable DGA framework extends to Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Greece, Italy, Latvia, Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Slovakia and Slovenia. These 17 are included through the common legal framework, not through 17 separately verified operating registers. Absence from the provider page does not mean an authority is missing or applications are impossible.

Germany's Data Governance implementing law of 12 May 2026 assigns federal functions; the Bundesnetzagentur explains its supervisory role. The Netherlands' official business portal directs providers to ACM. Spain and Austria also publish official registration instructions. Germany law, Germany regulator, Netherlands, Spain, Austria.

Current-law caution: the Digital Omnibus proposes restructuring the data acquis. The Council adopted a negotiating position on 21 October 2026; its notice still describes future negotiations with Parliament. That is not enacted repeal of the DGA. Do not confuse it with the separate AI simplification legislation adopted in June 2026. Council's current legislative-status statement.

Flanders and Finland deserve separate attention

Belgium—Flanders: the 2 December 2022 decree authorises the Flemish Data Utility in company form, now branded Athumi. Its appearance on the EU register links a statutory institutional vehicle with regulated data intermediation. The comparison is strong on trusted governance and practical infrastructure; it is not constitutive registration of private dataset title. Original decree, EU listing.

Finland: the Act on the Secondary Use of Health and Social Data, 552/2019, supports controlled reuse through Findata, permits and secure processing. Researchers apply for lawful access under specified purposes; they do not purchase title to people's underlying health information by registering. Current original-language legislation, Findata legislation guide.

The Database Directive 96/9/EC is another, older comparison: it provides qualifying database investment with protection against extraction/reutilisation. That is distinct from ownership of the underlying facts and from organisational registration. Original Directive. The EU Data Act concerns rights and duties around access and use, rather than a general data-title registry. Regulation (EU) 2023/2854.

Lesson: a commercial Manx foundation will not automatically qualify as an altruism organisation or a neutral intermediary. Interoperability needs a role-by-role assessment, plus separate privacy and international-transfer compliance.

United Kingdom and neighbouring financial centres

England and Wales; Northern Ireland

The Property (Digital Assets etc) Act 2025, c29, received Royal Assent and commenced 2 December 2025. Section 1 removes the obstacle that an object cannot be personal property merely because it is neither a thing in possession nor a thing in action. It extends to England and Wales and Northern Ireland, not Scotland. It neither declares all information property nor creates a data-asset registry. Exact enacted Act, ss1–2, Law Commission background.

The Data (Use and Access) Act 2025 separately enables Smart Data schemes, digital verification services and other data reforms. It should not be cited as a general dataset-ownership statute; individual schemes and commencement must be checked. Official Act collection, government explanation.

Jersey, Guernsey, Liechtenstein and Switzerland

Jersey: the Foundations (Jersey) Law 2009 offers a separate foundation vehicle. Holding eligible contractual/IP rights in an entity is an institutional parallel, but the law is not evidence of a constitutive data-asset register. Official consolidated Law.

Guernsey: the Foundations (Guernsey) Law 2012 provides another foundation comparison. No specialised data-asset-title regime was verified here. Regulator's legislation catalogue.

Liechtenstein: the Token and TT Service Provider Act, TVTG, dated 3 October 2019, and ordinance entered into force 1 January 2020. It regulates token-related rights and service providers. A token representing a claim to data rights is different from creating the underlying data rights; a service-provider register is different from dataset title registration. Official law record, FMA explanation.

Switzerland: its DLT reforms introduced ledger-based securities and related market infrastructure, with the remaining package in force 1 August 2021. This is useful for finance and transferable rights, not proof of registered ownership of datasets generally. Federal Council commencement statement.

United States: several distinct state-level comparisons

No general US foundation-based data-title register was verified. The most relevant examples address either a particular kind of information, a legal holding vehicle, digital assets, or data brokers.

This is a targeted state comparison, not a completed 50-state enactment audit. In particular, these broker examples are not claimed to be the entire October 2026 population of state broker laws. DAO and cryptocurrency legislation elsewhere is not silently counted as data-asset legislation.

Colorado's proposed “Digital Soul” register: close in concept, not established law

Colorado's 2025–2026 Initiative266 is unusually relevant. Legislative Council staff describe a proposal to recognise residents' biometric, behavioural and other defined data as inalienable intangible personal property, create a Master Deed registry, record permission grants/revocations, and distribute a proposed dividend or royalty. The official staff review is evidence of a filed and reviewed proposal—not enactment, ballot qualification, a working register or entitlement to payments. Related initiative filings should not be treated as successive enacted amendments. Original official staff memorandum, filed initiative text, official filing/status catalogue.

This is a closer proposal-level comparison for a data-rights registry and resident income than a conventional broker register. Its focus on individuals' inalienable rights differs from a commercial asset vested in a foundation. The legal, implementation and constitutional questions raised in the staff process remain material.

Lesson: the Island should explain whose rights it protects. A foundation's commercial rights and an individual's continuing privacy or genetic-data rights can coexist; one does not erase the other.

India and Singapore: usable data infrastructure without asset-title registration

India: the RBI's NBFC–Account Aggregator Directions of 2 September 2016 underpin a financial-data-sharing system launched in September 2021. Account Aggregators facilitate transfers on explicit customer consent. They are a comparison for accountable intermediaries, rather than owners buying title to customer data. Finance Ministry framework description, RBI directions, official launch history.

India's 2020 expert work on non-personal data proposed community representation and trustees; that report is a proposal, not an enacted data-property register. The original revised committee document is dated 16 December 2020. A later national framework approved 15 May 2026 concerns interoperable government databases and sharing for AI; it should not be conflated with enactment of the 2020 trustee proposals. Original committee report, preserved by a third-party host, official 2026 framework.

Singapore: IMDA's Trusted Data Sharing Framework provides common concepts, contractual resources and valuation guidance. SGTraDex supplies data-exchange infrastructure for supply chains. These are close practical comparators for confidence and efficient exchange, without demonstrating constitutive registration of data property. IMDA framework and original resources, IMDA on SGTraDex.

Lesson: a workable consent, authority and access network may generate value before investors attach value to a new legal asset category. Measure actual data reuse alongside registrations.

Australia and New Zealand: accreditation and controlled access

Australia—Commonwealth: the Data Availability and Transparency Act 2022 establishes the DATA Scheme. Accredited users and accredited data-service providers appear in a public register; participating entities enter data-sharing agreements. This is an operational access-governance regime for government data, not a universal market in privately owned datasets. Act compilation, current accredited-entity register, agreement requirements.

The separate Consumer Data Right accredits recipients and registers participants for consumer-authorised sharing. Applicants undergo accreditation and technical onboarding. Official application instructions, current providers.

New South Wales: the Data Sharing (Government Sector) Act 2015 authorises specified government sharing while preserving other legal requirements. South Australia: the Public Sector (Data Sharing) Act 2016 supports public-sector sharing and analytics. These are public data-governance comparisons, not asset-title regimes. NSW privacy regulator's explanation, South Australian Act and subordinate instruments.

New Zealand: the Customer and Product Data Act 2025, No14, establishes an access and authorisation framework, including accredited requestors. The official January 2026 consolidation is in force, but designation and sector implementation remain separate questions. It is not constitutive registration of ownership in data. Exact current Act.

UAE and Bahrain: jurisdictional and institutional parallels

Dubai: Law No26 of 2015 Regulating Data Dissemination and Exchange provides a statutory data-sharing framework, including public-authority functions and data-provider obligations. The reference to primary registers concerns managing and exchanging Dubai data, not general private dataset title. Official English translation.

DIFC: Digital Assets Law No2 of 2024 and the Foundations Law No3 of 2018 are relevant to digital property and holding structures. The particular 2024 digital-assets entry retrieved is marked Inactive in the legal database. It is therefore an historical comparator here, not an unqualified current-law citation. Its replacement/consolidation and the precise treatment of ordinary replicable data remain unresolved in this audit. Official law entry and status, DIFC legal database.

ADGM: the Foundations Regulations 2017 supply a foundation vehicle. That alone does not establish a specialised data-asset register. Original official regulations.

Bahrain: Legislative Decree No56 of 2018 concerns cloud-computing services for foreign parties, with designated-state arrangements under Decision No67 of 2021. It is a useful jurisdictional protection/data-hosting comparison, rather than data-asset property registration. Exact decree, implementing decision.

Saudi Arabia: SDAIA's Data Sharing Policy describes a National Data Bank and marketplace supporting governed sharing. A data marketplace is not, without additional law, an ownership register. Original policy.

Americas, Africa and Central Asia: additional screened comparisons

Canada: consumer-driven banking is a relevant controlled-sharing comparison. The Bank of Canada describes implementation and published proposed regulations; that wording does not prove a fully operational general registration system. Separately, the Privacy Commissioner's annual report records that Bill C27 died on the order paper in January 2025. Do not cite its proposed privacy/AI provisions as enacted law. Bank of Canada, official annual report.

Brazil: Open Finance is regulated sharing among eligible institutions at customer discretion, rather than general dataset ownership registration. The regulatory framework continues to change: the central bank publishes Joint Resolution21 of October 2026 amending the original Joint Resolution1 of 2020. Central bank explanation, October 2026 amendment.

Chile: Fintech Law21.521 and Open Finance General Rule514 provide another data-access comparison. The regulator announced technical amendments on 1 June 2026. This does not establish a generic data-title register or that every implementation phase has begun. Financial regulator's current implementation notice.

Colombia: Decree1389 of 2022 establishes governance for national data infrastructure and institutional coordination. It is an enacted data-governance framework, not evidence that registering a dataset creates a proprietary asset. Exact decree.

Rwanda: Cabinet approved the National Data Sharing Policy on 26 May 2025. The framework governs protected exchange among public institutions. Policy approval should not be reported as enactment of a data-ownership statute. Government approval announcement, original policy.

Kenya: Data Protection Act2019, s18, and the Data Protection (Registration of Data Controllers and Data Processors) Regulations2021 create an entity-compliance register. Registration does not establish ownership of the personal information processed. Original regulations, regulator guidance.

Kazakhstan: the Digital Code, No255-VIII of 9 January 2026, is a significant recent lead: the official English search text describes digital data and exchange/circulation platforms. A government notice says the Code entered into force in July 2026. Full operative provisions could not be retrieved, and official explanatory pages disagree by a day on commencement. This report therefore does not certify a data-property registry or precise commencement date. Official Code record, government commencement account, official legal navigator and caveat.

These regional entries are comparisons actually located, not a representation that the remaining countries in those regions were individually cleared. Hong Kong, Macao, Taiwan, Russia, the remaining US states, most Canadian provinces and many African, Latin American and Pacific jurisdictions still require dedicated instrument-level follow-up before making any absence claim.

What this means for the Isle of Man strategy

The evidence supports a specific position: build a jurisdiction where identifiable organisations can hold, govern and license well-defined data rights, with credible assurance and enforceable accountability for AI use. “We invented data as property” is neither necessary nor supported by this comparison.

Priorities suggested by the comparisons are:

1. Publish the complete legal route. Authenticated current Act, commencement, regulations, fees, forms, eligibility, appeal route and sample register entry. China's live service and Europe's actual provider registers make operational proof a basic competitive requirement.
2. Explain the extra right. State exactly what full registration creates, what pre-existing rights must be dedicated, what outsiders must respect, and which privacy, IP and contractual restrictions remain.
3. Design for useful international relationships. Study China's certificates, Korea's asset protection and valuation, Japan's controlled-sharing remedies, and EU neutrality rules. Mutual recognition requires legal agreements or applicable instruments; it does not follow from similar terminology.
4. Separate commercial and public-interest models. A revenue-generating DAF, a neutral intermediary and an altruism organisation have different incentives and legal conditions. Select deliberately for each use case.
5. Make agent permissions verifiable. Record the responsible legal person, the dataset/version, permitted AI uses, delegation limits, expiry, revocation and complaint route. Registration must not be marketed as unrestricted permission to train or deploy an agent.
6. Demonstrate customer value. Start with defined uses in maritime, aviation, insurance or another existing Manx cluster. Report actual applications, accepted/rejected registrations, assurance findings, licensing revenue and disputes. Financing should be reported separately from registration counts.

These are research recommendations, not adopted Manx policy. The next legal priority is the precise operative Manx text; the next comparative priorities are the national Chinese Guidelines and service conditions, Vietnam's exchange implementation, and resolution of the DIFC and Kazakhstan source gaps.