FCA warning to football clubs on sponsorship deals: a wider lesson on regulatory due diligence

In its press release of 3 June 2026, the regulator warned clubs not to enter into commercial arrangements with financial firms which are unauthorised and therefore lack permission to operate in the UK. It emphasised particular concerns regarding unauthorised crypto businesses and trading platforms, highlighting the regulatory and consumer protection risks associated with such entities. 

Although the warning is framed in terms of consumer protection, its significance is broader. 

It underlines a growing expectation across regulated and consumer-facing sectors that organisations should know who they are dealing with, confirm whether counterparties are subject to regulation and hold any required permissions before a relationship begins. This reflects a wider regulatory direction of travel in which responsibility for identifying and mitigating regulatory risk is no longer confined to authorised firms but is increasingly expected of organisations with access to consumers, markets or reputational platforms. While the Football Governance Act 2025 introduces a distinct licensing and oversight regime focused on financial sustainability and governance, it reinforces the importance of robust risk management and due diligence in clubs’ commercial decision-making. In that context, the FCA’s warning reinforces the expectation that organisations take proactive steps to understand and manage the regulatory status of those with whom they engage.

What has the FCA said?

The FCA’s concern is that some firms are using football sponsorships to gain credibility and visibility with UK consumers despite lacking the authorisation or approval needed to provide or promote financial products and services in the UK. 

The regulator’s point is a practical one: a shirt logo, stadium advertisement or club partnership may give the impression that a business is established, trustworthy and safe to use, but that branding does not say anything about whether the business is legally entitled to operate in the UK.

For supporters, the risk is obvious; if a firm is not authorised or otherwise permitted to market to UK consumers, individuals dealing with it may have limited protection if things go wrong. 

For clubs, however, the FCA’s warning is equally important. 

The FCA says these sponsorship arrangements can potentially expose clubs to regulatory risk, financial crime concerns and significant reputational damage. 

The FCA also makes it clear that due diligence is not a one-off exercise; clubs are expected to assess financial services sponsors before signing and to continue monitoring the position throughout the life of the deal. This approach closely mirrors established principles in anti-money laundering (“AML”) frameworks, where regulated firms are required to undertake ongoing customer due diligence and monitor relationships on a continuous basis, rather than relying solely on checks carried out at onboarding. The underlying message is consistent: risk assessment must be dynamic, and organisations are expected to identify and respond to changes in a counterparty’s regulatory status over time.

Why this matters beyond football

Although the immediate focus is football, the underlying principle applies across many industries.

Across sectors, regulated entities are often required to check whether customers and counterparties are properly regulated where necessary. That may involve compliance and anti-money laundering checks, confirming required approvals, assessing suppliers against legal and sanctions requirements, and ensuring commercial arrangements do not expose customers to unlawful activity or avoidable harm.

Seen in that context, the FCA’s intervention reflects a continuing shift in regulatory expectations. Its focus is not only on firms carrying on regulated activity, but also on those that provide access, credibility or audience reach to potentially non-compliant businesses.

Therefore, football organisations cannot always present themselves as passive recipients of sponsorship, advertising revenue or partnership opportunities if those arrangements help bring an unauthorised business in front of consumers.

What does this mean in practice?

For football clubs and other organisations entering sponsorship or partnership arrangements, the key point is that regulatory due diligence should sit alongside commercial due diligence.

That means identifying at the early stages whether a proposed sponsor operates in a regulated space, whether it has the necessary authorisation, registration or approval in the UK, and whether the arrangement could enable the sponsor to market financial products to consumers in a way that engages the UK financial promotion regime or raises broader consumer protection concerns.

Where a sponsor is active in a higher-risk area such as cryptoassets, trading services or investments, that exercise is likely to require more than checking a website or relying on contractual assurances. Organisations may need to verify the sponsor’s status on the relevant register, understand precisely which entity is contracting, assess whether the arrangement could involve UK-facing financial promotions requiring approval, and consider whether the deal structure itself could create exposure where the sponsor’s activities are unauthorised or otherwise non-compliant with UK regulatory requirements. Internal legal, compliance and risk teams should be involved at an early stage so that they can shape the transaction rather than simply sign off on it at the end.

Ongoing monitoring also matters. 

Regulatory risks can evolve over time. A firm may be added to a warning list, become subject to regulatory restrictions, or alter the way in which it markets to UK customers during the life of a sponsorship. Contracts should therefore include clear termination rights, information obligations and reputational risk protections, supported by  governance processes to ensure concerns are identified and escalated promptly.

A wider compliance message

The FCA’s warning to football clubs is likely to resonate beyond sport.

It reflects a broader regulatory expectation that organisations should carry out meaningful checks on the businesses they engage with, particularly where regulated services may be offered to consumers. The question is not just whether a deal is commercially attractive, but whether it can be justified from a legal, compliance and reputational risk perspective.

For clubs, the immediate message is that sponsorship arrangements involving financial services firms should be approached with heightened caution. For businesses in other sectors, the lesson is similar. 

If a counterparty needs to be regulated in order to carry out its proposed activities, that position should be verified carefully and documented appropriately. In a regulatory environment that increasingly looks at distribution models, consumer outcomes and gatekeeper responsibility, failing to ask those questions at an early stage can give rise to avoidable legal and commercial risks.