The Contested Stack
Your Next Acquisition May Already Have Westminster’s Attention
On 22 April 2026, the Chancellor of the Duchy of Lancaster signed a final order under the National Security and Investment Act 2021 in respect of the acquisition of Manx Telecom Trading Limited by Dunlop Bidco Limited -- the acquisition vehicle for CVC Capital Partners and Jersey’s JT Group.
The order allowed the transaction to proceed. It also attached conditions.
Manx Telecom must continue to fulfil certain services provided to the UK Government in support of national security for as long as the relevant contracts remain in force. The new owners must establish a dedicated Cyber Security Group, ring-fenced from the rest of the business, to carry out those government activities and maintain the associated security posture.
No Tynwald debate preceded those conditions. No Manx minister negotiated them. They were imposed by Westminster, on infrastructure on Manx soil, under legislation the Isle of Man had no hand in drafting and no vote in passing.
If you own, operate, or are considering acquiring digital infrastructure on this island, that should give you pause.
Why Westminster Has the Reach
The Isle of Man is not part of the United Kingdom. That distinction, well understood in financial services and tax contexts, is less well understood when it comes to digital infrastructure -- and the gap between perception and reality has consequences.
The National Security and Investment Act 2021 gives Westminster the power to intervene in acquisitions of entities it deems sensitive to UK national security. It does not require the entity to be UK-based. It requires the entity to be a qualifying entity under the Act -- and Manx Telecom, as a supplier of services to UK Government departments in support of national security, qualified.
The constitutional relationship between the IoM and the UK has always meant that certain functions flow through Westminster regardless of the island’s nominal autonomy. Spectrum licensing is one of them. The Wireless Telegraphy (Isle of Man) Order 2007 (SI 2007/278) extends the UK’s Wireless Telegraphy Act 2006 to the island, with the effect that Ofcom manages radio frequency allocation for the IoM. The IoM is not a member of the International Telecommunication Union in its own right -- it operates under the UK’s ITU umbrella. CURA licenses the network operator. Ofcom licenses the spectrum the network uses. You cannot have one without the other.
The practical effect is that Westminster holds a structural position over any significant wireless communications activity on the island without ever needing to exercise it visibly. A 5G rollout, a satellite gateway operation, a new ground station -- any of these can be constrained through spectrum scheduling without a Tynwald vote, without a public consultation, and without the operator necessarily understanding why their licence conditions have changed until after the fact. The NSIA order made Westminster’s reach visible in one transaction. The spectrum architecture means it was always there.
The Isle of Man occupies a regulatory uncanny valley. It is not a UK county, entitled to parliamentary representation and subject to full Westminster oversight. It is not a sovereign state, with its own seat at international regulatory tables and its own capacity to set the terms on which external parties use its territory. It takes the risks of strategic significance without the benefits of strategic voice. When the NSIA review was triggered, there was no Manx chair at the table. There will not be one next time either.
What Manx Telecom Actually Carries
To understand why the NSIA conditions are structured as they are, you need to understand what Manx Telecom’s infrastructure actually does -- beyond providing broadband and mobile connectivity to 85,000 people.
The Isle of Man sits at the centre of the Irish Sea, equidistant from the coasts of England, Scotland, Ireland, and Wales. That geography has made the island a node in UK communications and surveillance architecture continuously since the Second World War. The relationship between Manx infrastructure and UK national security functions is not new. It is simply more formally documented now than it was before.
The Cyber Security Group condition is not boilerplate. It is Westminster structurally ring-fencing operational control of infrastructure that carries -- or provides backhaul for -- functions with national security implications. The new owners did not design that condition. They accepted it as the price of completing the transaction.
Any future acquirer of Manx Telecom, or of any entity with comparable infrastructure exposure, will face the same calculation.
The Carnane Cautionary Tale
The NSIA order concerns Manx Telecom. A parallel story at Carnane, Braddan, illustrates what happens when the commercial and regulatory dynamics of Manx digital infrastructure are not understood clearly by the parties making decisions about it.
The Carnane Radio Site, on a hilltop near Upper Howe Farm on the Old Castletown Road, is owned by BlueWave Communications Limited, a subsidiary of aql, a Leeds-based telecommunications firm. From late 2021 until June 2025, it served as a major gateway for Starlink -- SpaceX’s low-earth-orbit satellite network. Nine radomes provided Starlink’s gateway infrastructure for UK and Irish coverage. The planning history is public record: PA 16/00266/B, PA 17/00082/B, and PA 19/00010/B document the site’s development from a basic ground station to an installation capable of hosting four 11-metre parabolic dishes.
In June 2025, the radomes were dismantled. Irish-registered trailers removed them from the site. Starlink had left.
The reason matters. Running a satellite ground station at scale requires substantial terrestrial backhaul -- on an island, that means subsea fibre. The Isle of Man’s subsea fibre infrastructure includes capacity operated by e-llan Communications Limited and Manx Cable Company Limited, both subsidiaries of Manx Utilities, the government-owned utility. It is access to that government-owned capacity that sits at the centre of the complaint.
In April 2025, BlueWave filed a formal complaint with CURA. Information Notice 09/25, dated 10 April 2025, formally opened an investigation into alleged anti-competitive practices -- specifically that e-llan and/or Manx Cable were engaging in refusal to supply and related conduct that made subsea fibre backhaul access difficult or prohibitively expensive for private operators.
CURA’s Preliminary Relevant Market Definition and Initial Assessment of Market Power (Notice 25/25, 23 September 2025) assessed whether the government-owned fibre provider held significant market power in a way that distorted competition. The investigation remains open as of April 2026.
Industry analysis widely identifies the fibre access problem as a primary factor in Starlink’s commercial decision to leave. The site was not technically inadequate -- the 11-metre dishes approved under PA 19/00010/B indicate the opposite. The economics were broken.
The consequences are not abstract. The island’s subsea cables are its primary connection to the world and a credible vulnerability -- deliberate cable cutting has occurred in European waters in recent years. Satellite connectivity is the failover that keeps emergency services communicating and remote communities connected if the cables fail. A government-owned fibre monopoly allegedly pricing out the operators providing that resilience layer is not a regulatory footnote. It is a strategic own goal.
The IoM Government’s infrastructure subsidiary may have driven out the resilience infrastructure that Westminster’s national security apparatus was simultaneously seeking to protect elsewhere on the island. That is a description of what the public record shows -- and it is precisely the kind of unjoined thinking that a coherent digital sovereignty strategy would prevent.
The Due Diligence Question
Amazon Kuiper -- widely expected to be the next significant tenant at Carnane following Ofcom licensing activity in early 2025 -- will operate under spectrum conditions set in London, on a site owned by a Leeds company, on Manx soil. CURA will issue the network licence. Ofcom will have issued the spectrum licence. Tynwald will not have been consulted.
That is the current state of digital sovereignty on the Isle of Man -- not as a political complaint, but as a factual description of the regulatory architecture.
For anyone with commercial exposure to Manx digital infrastructure, the questions that follow from the NSIA order are practical ones:
Does your asset, or the asset you are considering acquiring, provide services to UK Government departments or support functions with national security implications? Does it carry emergency services communications, provide backhaul for civil aviation or military comms infrastructure, or operate as part of the island’s resilience architecture? Is it dependent on subsea fibre access controlled by a government-owned monopoly whose pricing behaviour is currently under regulatory investigation?
These are due diligence questions. The NSIA order demonstrates that Westminster will ask them whether or not you have. The difference is that Westminster’s version comes with conditions attached -- conditions you will not have negotiated, a Cyber Security Group you will not have budgeted for, and obligations that run for as long as the relevant government contracts remain in force.
The same question applies with equal force to the digital assets sector. The Isle of Man actively promotes itself as a jurisdiction for digital asset infrastructure -- tokenisation platforms, blockchain infrastructure, the broader digital economy stack. That pitch implicitly assumes the island has sovereign control over the digital infrastructure underpinning those assets. The NSIA order demonstrates that Westminster’s reach does not stop at the twelve-mile limit. Any digital asset platform with connectivity, data routing, or financial services infrastructure dependencies that touch UK government functions is a potential qualifying entity under the Act. Whether anyone in the digital assets sector has assessed that exposure is an open question. Westminster will not wait for the answer.
On the available evidence, the island’s digital infrastructure is not a Sovereign Stack. It is a Contested Stack -- and the contest is not one in which the Isle of Man currently has much of a voice.
The question for Tynwald, for the Cabinet Office, and for anyone considering a position in Manx digital assets or infrastructure, is the same: at what point does understanding the architecture you are governing, acquiring, or depending upon become a prerequisite rather than an afterthought?
The Sovereign Auditor covers cybersecurity, data protection, and digital sovereignty from the Isle of Man. Sources: NSIA Final Order (gov.uk, 22 April 2026); CURA Information Notice 09/25 (cura.im, 10 April 2025); CURA Notice 25/25 Preliminary Relevant Market Definition (cura.im, 23 September 2025); IoM Planning Portal references PA 16/00266/B, PA 17/00082/B, PA 19/00010/B; Wireless Telegraphy (Isle of Man) Order 2007 (SI 2007/278).