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The Football Governance Act 2025 (FGA) came into force in July 2025, ushering in a new regulatory framework for the top five tiers of English men's professional football. At its centre is the Independent Football Regulator (IFR), a statutory body whose core purpose is to equip clubs with the tools they need to thrive, by setting minimum standards for financial sustainability and governance, and by safeguarding key elements of club heritage.
The IFR does not replace existing football authorities. It operates independently but is expected to work collaboratively with the leagues and the FA. Leagues may continue to apply their own rules but are now subject to scrutiny of the IFR in certain respects. The IFR also oversees clubs, enforcing various rules aligned to the core objectives of the FGA.
The IFR's approach draws heavily on the model adopted by the Financial Conduct Authority (FCA), and the two bodies have entered into a memorandum of understanding to facilitate co-operation and information-sharing. Find out more about the relationship between the FCA and the IFR.
Implications of the IFR regime
The licensing regime
The IFR regime is built around a licensing system. All clubs will need to hold a provisional IFR licence to compete from the 2027/28 season. Provisional licences will be valid for no more than three years with compliant clubs then being transitioned to a full licence.
From the provisional licence stage onwards, all clubs must comply with four Mandatory Licence Conditions:
- Financial plans: clubs are required to submit and comply with a financial plan. If there are material changes, it must be re-submitted to the IFR.
- Corporate governance statement: clubs are required to submit a corporate governance statement to the IFR explaining how the club applies the IFR’s corporate governance code and what actions they are taking to improve equality, diversity and inclusion. It must also be published online and updated every two years.
- Fan consultation: clubs must establish a group of persons to act as representatives of the club’s fans and regularly consult with them on relevant matters (including on matters relating to the club’s heritage, such as its home ground, name, logo and shirt colour, as well as ticket prices). An annual fan consultation report must be submitted to the IFR, which may then request further information or evidence.
- Annual declaration: clubs must submit an annual declaration to the IFR about whether or not they have appropriate non-financial resources to enable it to operate (including, for example, human resources, facilities, risk management structures, technology and data protection systems, IP rights in club marks, and the right to use player imagery).
To be granted a full licence, a club must demonstrate to the IFR that it meets ‘thresholds’ which reflect the Mandatory Licence Conditions. The IFR must be satisfied that the club has appropriate financial resources, non-financial resources, and fan engagement arrangements in place.
If the IFR considers it necessary for clubs to achieve compliance, it may impose amended Mandatory Licence Conditions or Discretionary Licence Conditions.
Clubs can be sanctioned (including via financial penalties) for non-compliance and, ultimately, the IFR can revoke or suspend a licence (albeit there are safeguards in place to ensure the club has opportunities to rectify the position before the IFR takes such action).
The Owners, Directors and Senior Executives suitability test
A central feature of the licensing framework is the enhanced "Owners, Directors and Senior Executives" (ODSE) suitability test. Modelled closely on the FCA's Senior Managers Regime, this test assesses whether individuals are fit and proper to own, control or manage a football club, judged by reference to integrity, financial soundness and (for senior managers) competence. It applies to owners holding more than 25% of a club or exercising significant influence, as well as individuals in designated senior management roles.
Sanctions may be imposed for a range of infringements and may, in particular, include financial penalties such as:
- For owners, the maximum financial penalty may be set at 10% of the club's total revenue as a fixed amount, 10% of the club's daily revenue as a daily rate, or a combination of both; and
- For senior managers, penalties can be personal. A fixed penalty may be the higher of 10% of remuneration or £75,000, and a daily penalty the higher of 10% of daily pay or £25,000 per day.
Find out more about how owners and those in senior management function roles are affected.
Duties of clubs and leagues
The FGA provides for various standalone duties on clubs and leagues, which the IFR has powers of investigation and enforcement in respect of. These duties on clubs include obligations:
- not to compete in a prohibited competition (a key provision of the FGA which seeks to prevent the threat that was seen by the plan for the breakaway European Super League);
- not, without approval or the IFR, to dispose of the club’s home ground, relocate, or appoint an administrator;
- not, without approval or the FA, to change the club’s name, logo or shirt colour.
Parachute payments
Possibly the most publicised aspect of the regime is the IFR’s role in determining the distribution of revenue between leagues. Commonly referred to as ‘parachute payments’, the IFR has a role in facilitating mediation and, where agreement between leagues can still not be reached, the IFR has the power to make orders as to the distribution of ‘relevant revenue’.
The "State of the Game" report
The FGA also requires the IFR to produce a "State of the Game" report, which will be the first independent, comprehensive analysis of men's professional football in England. The report's findings are expected to inform the IFR’s licence conditions, the Football Club Corporate Governance Code, and the IFR's approach to risk-based supervision and enforcement. The IFR has indicated that it plans to publish a draft report in 2026, with the final version due in 2027.
Check out our insight detailing the "State of the Game" report and what it will cover.
How we can help
The IFR is a new body, and its regulatory framework remains in its early stages. As the "State of the Game" report and ongoing supervisory work yield further findings over the coming years, the regime is likely to evolve, with licence conditions, governance standards and enforcement practices all subject to further refinement and change. We have a dedicated sport group spanning corporate, commercial, real estate, dispute resolution, immigration and technology – meaning we can advise on all aspects of the IFR’s impact on clubs.
Check out our Independent Football Regulator hub for regular updates and our timeline of Independent Football Regulator activity.
The IFR does not replace existing football authorities. It operates independently but is expected to work collaboratively with the leagues and the FA. Leagues may continue to apply their own rules but are now subject to scrutiny of the IFR in certain respects. The IFR also oversees clubs, enforcing various rules aligned to the core objectives of the FGA.
The IFR's approach draws heavily on the model adopted by the Financial Conduct Authority (FCA), and the two bodies have entered into a memorandum of understanding to facilitate co-operation and information-sharing. Find out more about the relationship between the FCA and the IFR.
Implications of the IFR regime
The licensing regime
The IFR regime is built around a licensing system. All clubs will need to hold a provisional IFR licence to compete from the 2027/28 season. Provisional licences will be valid for no more than three years with compliant clubs then being transitioned to a full licence.
From the provisional licence stage onwards, all clubs must comply with four Mandatory Licence Conditions:
- Financial plans: clubs are required to submit and comply with a financial plan. If there are material changes, it must be re-submitted to the IFR.
- Corporate governance statement: clubs are required to submit a corporate governance statement to the IFR explaining how the club applies the IFR’s corporate governance code and what actions they are taking to improve equality, diversity and inclusion. It must also be published online and updated every two years.
- Fan consultation: clubs must establish a group of persons to act as representatives of the club’s fans and regularly consult with them on relevant matters (including on matters relating to the club’s heritage, such as its home ground, name, logo and shirt colour, as well as ticket prices). An annual fan consultation report must be submitted to the IFR, which may then request further information or evidence.
- Annual declaration: clubs must submit an annual declaration to the IFR about whether or not they have appropriate non-financial resources to enable it to operate (including, for example, human resources, facilities, risk management structures, technology and data protection systems, IP rights in club marks, and the right to use player imagery).
To be granted a full licence, a club must demonstrate to the IFR that it meets ‘thresholds’ which reflect the Mandatory Licence Conditions. The IFR must be satisfied that the club has appropriate financial resources, non-financial resources, and fan engagement arrangements in place.
If the IFR considers it necessary for clubs to achieve compliance, it may impose amended Mandatory Licence Conditions or Discretionary Licence Conditions.
Clubs can be sanctioned (including via financial penalties) for non-compliance and, ultimately, the IFR can revoke or suspend a licence (albeit there are safeguards in place to ensure the club has opportunities to rectify the position before the IFR takes such action).
The Owners, Directors and Senior Executives suitability test
A central feature of the licensing framework is the enhanced "Owners, Directors and Senior Executives" (ODSE) suitability test. Modelled closely on the FCA's Senior Managers Regime, this test assesses whether individuals are fit and proper to own, control or manage a football club, judged by reference to integrity, financial soundness and (for senior managers) competence. It applies to owners holding more than 25% of a club or exercising significant influence, as well as individuals in designated senior management roles.
Sanctions may be imposed for a range of infringements and may, in particular, include financial penalties such as:
- For owners, the maximum financial penalty may be set at 10% of the club's total revenue as a fixed amount, 10% of the club's daily revenue as a daily rate, or a combination of both; and
- For senior managers, penalties can be personal. A fixed penalty may be the higher of 10% of remuneration or £75,000, and a daily penalty the higher of 10% of daily pay or £25,000 per day.
Find out more about how owners and those in senior management function roles are affected.
Duties of clubs and leagues
The FGA provides for various standalone duties on clubs and leagues, which the IFR has powers of investigation and enforcement in respect of. These duties on clubs include obligations:
- not to compete in a prohibited competition (a key provision of the FGA which seeks to prevent the threat that was seen by the plan for the breakaway European Super League);
- not, without approval or the IFR, to dispose of the club’s home ground, relocate, or appoint an administrator;
- not, without approval or the FA, to change the club’s name, logo or shirt colour.
Parachute payments
Possibly the most publicised aspect of the regime is the IFR’s role in determining the distribution of revenue between leagues. Commonly referred to as ‘parachute payments’, the IFR has a role in facilitating mediation and, where agreement between leagues can still not be reached, the IFR has the power to make orders as to the distribution of ‘relevant revenue’.
The "State of the Game" report
The FGA also requires the IFR to produce a "State of the Game" report, which will be the first independent, comprehensive analysis of men's professional football in England. The report's findings are expected to inform the IFR’s licence conditions, the Football Club Corporate Governance Code, and the IFR's approach to risk-based supervision and enforcement. The IFR has indicated that it plans to publish a draft report in 2026, with the final version due in 2027.
Check out our insight detailing the "State of the Game" report and what it will cover.
How we can help
The IFR is a new body, and its regulatory framework remains in its early stages. As the "State of the Game" report and ongoing supervisory work yield further findings over the coming years, the regime is likely to evolve, with licence conditions, governance standards and enforcement practices all subject to further refinement and change. We have a dedicated sport group spanning corporate, commercial, real estate, dispute resolution, immigration and technology – meaning we can advise on all aspects of the IFR’s impact on clubs.
Check out our Independent Football Regulator hub for regular updates and our timeline of Independent Football Regulator activity.
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