The Independent Football Regulator - What you need to know

We have previously commented on the IFR, particularly the Owners’, Directors’ and Senior Executives regime. In this article, we focus in more detail on the purpose of the IFR.

Historically, clubs have been regulated primarily through league contractual regimes which have primarily been focused on sporting integrity and competition rules.  The introduction of the IFR does not seek to do away with this, but introduces a new model to run in parallel and intended to give statutory independent oversight of clubs focused on long-term sustainability and financial resilience of the professional game.

Unlike the Premier League (“PL”), English Football League (“EFL”), or the National League (“NL”), the IFR is not a competition organiser but a statutory regulatory body established under the Football Governance Act 2025 (“the Act”), with defined legal objectives, powers and duties governing how and when it may act.

Why has the IFR been established?

The creation of the IFR reflects longstanding and systemic concerns about the financial stability of English football and the sustainability of the clubs that compete within its main competitions.

In recent history, there have been a number of high-profile club failures which have highlighted these concerns. For example, Bury FC, were expelled from the EFL in 2019 following financial collapse. 

Furthermore, there has been growing concerns over protecting the heritage of English football, including the relationship between clubs and their supporters. The attempted launch of the controversial European Super League in 2021, whilst ultimately unsuccessful, highlighted the extent to which major structural decisions affecting the future of clubs and competitions could be pursued without meaningful regulatory oversight of fan engagement.

When considered together, these types of issues and incidents present fertile grounds for a more robust and independent regulator, which the IFR intends to be. The main objectives of the IFR are set out in the Act, and are to:

• Promote the financial soundness of individual clubs;
• Promote the systemic financial resilience of English football as a whole; and
• To safeguard the heritage of the game.

Which clubs are affected?

The IFR licensing regime applies to clubs operating in the top five divisions of English football, in other words, clubs operating in the:

• Premier League
• Championship
• League One
• League Two
• National League.

In total, 116 clubs across the top five divisions will be brought into the regulatory scope of the IFR.

Who will be regulated?

Given the wide ranging, and often complex structures surrounding football clubs, the relevant regulated entity (i.e. the entity that will need a licence under the IFR) will be the legal entity that actually operates the club. However, the IFR does have the power and will look across group structures where necessary to understand financial risk, funding arrangements and governance. In practice, this means that while only the club operating entity is licensed, entities comprising the wider group also need to be acutely aware of where financial risk, governance or decision making sits.

The Licensing Regime

Central to the IFR framework is licensing regime. All in-scope clubs must apply for and obtain a provisional licence in order to play in 2027-28 season. The application window for this will open during the 2026-27 season, with the application window from November 2026 to February 2027. The full licensing rules and guidance are expected to be published by 1 July 2026.

The IFR states it will aim to make decisions on provisional licence applications by the end of May 2027, ahead of league Annual General Meetings.

While clubs will ultimately be expected to eventually transition to a full licence by 2030 (for clubs licensed in 2027), but for the time being the focus for clubs will be to apply and obtain a provisional license, which will require them to demonstrate compliance with a set of threshold requirements. 

The threshold requirements are a set of fundamental conditions broadly relating to a club’s financial soundness, governance, resources, and engagement with supporters. It is important to note that these requirements are not assessed by reference to rigid thresholds or arbitrary numbers. Instead, the IFR is obliged to take a principles based, forward looking view, focusing on whether a club understands its risks and is managing them appropriately. As such, the focus for clubs ought to be the quality of planning, governance and decision making, and demonstrating ongoing, resilient operation with the same.

In particular, clubs should be focusing on:

- Financial Planning and Resilience

Clubs should review the robustness of their financial plans, including the sustainability of funding arrangements, liquidity under downside scenarios, stress testing financial plans and the credibility of mitigation strategies, and demonstrating an in depth awareness on the clubs financial risks and how these are managed.

- Governance Structures and board oversight

Relevant boards should consider whether current governance arrangements are fit for purpose and provide effective oversight and challenge. Consideration should be had to allocate responsibility for financial and risk management. In practice, this may involve wholesale review of board composition, decision making processes and internal documentation.

- Ownership structures and funding flows

As mentioned above, given the IFR’s ability to look beyond the actual regulated entity itself, club should ensure there is clarity around group structures, intra-group funding arrangements and where influence and decision making sit in practice. These should be clearly mapped out, logical, and up to date. Complex or opaque structures will naturally attract closer regulatory scrutiny.

- Internal systems and operational capability

Clubs should assess whether they have appropriate and fit for purpose financial reporting systems, risk management processes, and internal controls, tools and resources to support ongoing compliance and engagement with the IFR.

There is no “one size fits all” model in this regard. Consistent with its principles based and supervision led approach, the IFR will assess internal capability proportionately, taking into account the size, complexity and risk profile of each club. The focus will therefore be on whether a club’s systems and resources and sufficient and effective for its purposes, rather then whether they meet a prescriptive standard.

- Fan engagement and heritage processes

Clubs should ensure that they have structured and meaningful fan engagement mechanisms in place, and clearly documented processes for consulting supporters on relevant matters.

This is an area of the regime that is inherently more qualitative. The IFR’s focus is less on prescriptive processes and more on the substance and effectiveness of engagement, including whether consultation is genuine, proportionate and capable of informing decision making. As such, clubs should be mindful that these will likely involve a degree of supervisory judgment.

Where risks may be identified, the IFR has the power to impose discretionary licence conditions which are tailored to the specific risk/s identified, intended to be proportionate, and subject to review over time. These are not intended as a punishment but as a method of managing risk proactively. 

However, given discretionary licence conditions would be a matter of public knowledge, there is a risk that imposition of the same can cause reputational or commercial implications for clubs, and so clubs would understandably seek to avoid these.

Owners, Directors and Senior Executives

In addition to the licensing regime, the IFR also brings with it an Owners, Directors and Senior Executives regime, which applies to owners, directors, key decision makers, and anyone exercising a significant influence or control over a club.

The ODSE regime interacts closely with the licensing regime, particularly during ownership changes, key personal changes, or governance transitions. However, unlike the licensing regime, the ODSE regime is inherently binary in that individuals are either approved as suitable and eligible or they are not.

This reflects the purpose of the ODSE regime which is to assess whether individuals are fit to own or exercise control or positions of power within clubs. While licensing involves ongoing qualitative and judgment based assessment, ODSE determinations are more definitive. Individuals either meet the required standards or they do not.

A different type of Regulator

Broadly speaking, the IFR represents a shift from regulatory models based on rules and periodic compliance, to one based on continuous supervision and forward-looking judgment. 

In practical terms, this means the question for clubs is no longer simply “are we compliant?”, but instead “Are we demonstrably sustainable, well governed and resilient now and for the long term?”

The IFR regime introduces a new layer of accountability and transparency, and for well-run clubs, it should provide a structured and proportionate framework. For others, it will bring earlier, and perhaps more public scrutiny, and intervention when risks emerge.

Whilst most eyes will be focused on World Cup this summer, measured and careful preparation for clubs at this stage, particularly in relation governance, financial planning and internal capability, will be critical to ensuring a smooth transition into the new regime and minimise any friction during the licensing process.