Global view

Different laws. Different kinds of trust.

Compare the closest selected approaches to data registration, protection and stewardship. Similar language does not guarantee similar legal effects.

14 selected comparisons

AsiaRegistration

China

National trial operating · 11 September 2026

A national data-property registration service aggregates results from authorised registration institutions. Certificates support evidence of rights; no dedicated foundation is required.

Distinction: Evidentiary registration under administrative guidelines should not be equated with the Manx Bill’s constitutive mechanism.

Original / official source ↗
AsiaProtection

South Korea

Enacted framework · Act of 19 October 2021; amended text

Article 12 expressly protects economically valuable data assets produced through substantial investment. The framework also addresses valuation and quality certification.

Distinction: Protection against unfair appropriation, rather than a foundation-based title register.

Original / official source ↗
AsiaProtection

Japan

Enacted framework · Official bilingual Act

Qualifying shared data with limited access is protected against specified wrongful acquisition, disclosure and use.

Distinction: Conduct-based protection, with no general data-title registration requirement.

Original / official source ↗
AsiaRegistration

Vietnam

Data Law and exchange rules · Law effective 1 July 2025

The Data Law governs digital data and data products and services. Exchange rules took effect on 25 September 2026.

Distinction: An enacted market framework does not establish that every envisaged registration service is accepting applicants.

Original / official source ↗
EuropeStewardship

European Union

Applicable DGA; live registers · Applies from 24 September 2023

Regulated intermediaries and recognised data-altruism organisations support trusted sharing across a common legal framework.

Distinction: Registers organisations and their roles, rather than ownership of each dataset.

Original / official source ↗
EuropeStewardship

Belgium · Flanders

Statutory data utility · Decree of 2 December 2022

Athumi combines a statutory institutional vehicle with a listed data-intermediary role.

Distinction: Trusted facilitation infrastructure, rather than constitutive title to a data asset.

Original / official source ↗
EuropeStewardship

Finland

Controlled secondary use · Act 552/2019

Findata provides a statutory route for permitted secondary use of health and social data.

Distinction: Authorised access within defined purposes does not transfer ownership of underlying health information.

Original / official source ↗
EuropeProtection

England, Wales & Northern Ireland

Digital-property Act in force · 2 December 2025

The Act removes the obstacle that a thing cannot be property merely because it is neither a thing in possession nor a thing in action.

Distinction: It does not declare every dataset property or establish a data-asset register. It does not extend to Scotland.

Original / official source ↗
OceaniaStewardship

Australia

Accreditation and sharing · DATA Scheme · Act 2022

Accredited users and service providers participate in controlled sharing of government data.

Distinction: A participant register and lawful access framework, rather than ownership by dataset registration.

Original / official source ↗
AsiaStewardship

India

Account Aggregators operating · Directions 2016; launch 2021

Regulated intermediaries facilitate consent-based transfers of financial information.

Distinction: The customer’s data is not transformed into an asset owned by the intermediary.

Original / official source ↗
AmericasProposal

United States · Colorado

Filed initiative; not established law · 2025–2026 Initiative 266

A reviewed proposal describes a Master Deed register for residents’ data rights and proposed royalties or dividends.

Distinction: A filed proposal is not enactment, ballot qualification, operational registration or an entitlement to payments.

Original / official source ↗
AmericasProtection

United States · Florida

Narrow genetic-data rule · Florida Statutes §760.40

Specific property language applies to a person’s DNA sample and DNA-analysis results, subject to the statutory conditions.

Distinction: Individual genetic-information control is distinct from a commercial dataset-title register.

Original / official source ↗
AsiaStewardship

Singapore

Framework and infrastructure · IMDA trusted-sharing resources

Trusted Data Sharing Framework resources and SGTraDex address practical confidence and exchange.

Distinction: An exchange or contractual framework is not itself a property-title registry.

Original / official source ↗
Middle EastProtection

Bahrain

Cloud jurisdiction framework · Legislative Decree 56/2018

Law addresses cloud-computing services provided to foreign parties, with implementing arrangements.

Distinction: Jurisdictional hosting protections differ from registered ownership of data.

Original / official source ↗
Scope matters. These are selected comparisons from research checked on 30 October 2026, not a current-law clearance of every country or state. The detailed study includes 17 named Chinese pilots, the 27-state EU framework and US state examples. Read the full comparison →