‘For Love of the Game’: Introducing the Independent Football Regulator

The Football Governance Act 2025 has introduced a statutory framework for the regulation of English football. Established under the Act, the Independent Football Regulator (IFR) aims to protect clubs’ financial soundness, strengthen financial resilience across the game and safeguard football heritage for fans and local communities.

For clubs within scope, the framework introduces requirements across licensing, financial planning, corporate governance, ownership and Senior Management, fan engagement and club heritage. Boards and senior leaders should understand which obligations already apply and prepare the arrangements needed for licensing.

The IFR published its final licensing rules and guidance on 1 July 2026. Clubs competing in the top five divisions must apply for and obtain a provisional licence ahead of the 2027/28 season. The provisional licence application window opens on 2 November 2026 and closes on 26 February 2027. However, the regime is already operational in important areas, including ownership and Senior Management assessments and additional statutory duties.

Who is captured by the IFR Framework

The club licensing framework covers the top five tiers of English men’s football:

The Premier League;
Championship;
League One;
League Two; and
National League.

The regime also has implications for:

Existing and Prospective club owners;
Club Directors; and
Club Senior Executives.

Additionally, clubs considering investment, changes in ownership or senior appointments need to assess the relevant IFR requirements as part of their decision-making and transaction planning.

What Clubs Need to Get Right

IFR Readiness and Licensing

IFR licensing introduces an ongoing regulatory relationship. Clubs will need to prepare their provisional licence applications and maintain compliance with the conditions attached to their licences.

The published framework includes a Strategic Business Plan forecasting template, corporate governance reporting guidelines and ongoing declarations. Clubs should assess their readiness, identify gaps in supporting evidence and establish a practical plan for preparing their submissions.

Financial Resilience and Prudential Governance

Financial sustainability is central to the regime. Clubs must demonstrate responsible financial management, supported by viable budgets and effective risk management. Preparation should therefore include reviewing financial forecasting controls, liquidity monitoring, funding dependencies and the information provided to the Board.

Clubs should understand how their plans respond to financial pressures and ensure that significant assumptions receive appropriate challenge.

Corporate Governance and Board Oversight

Licensed clubs must produce a statement explaining how they apply the IFR’s Football Club Corporate Governance Code. This places emphasis on transparency, accountability and effective Board oversight.

Clubs should review decision-making responsibilities, reporting arrangements and internal controls. Board minutes, management information and records of challenge can help demonstrate how governance operates in practice.

Owners, Directors and Senior Executives

The Owners, Directors and Senior Executives (ODSE) regime is already live. The IFR’s powers relating to incumbent owners and Senior Managers took effect in December 2025, with assessments for new owners and Senior Managers beginning on 5 May 2026.

Clubs should establish processes for identifying relevant individuals, assessing proposed appointments and ownership changes, gathering supporting information and meeting applicable notification requirements. Relevant suitability considerations include honesty, integrity, competence and financial soundness.

Complyport’s previously published article, ODSE: SM&CR for Football Clubs?, explores the parallels between football’s ODSE framework and financial services regulation, including individual accountability, suitability assessments and ownership transparency. It provides further insight into the practical governance considerations for club owners, directors and senior executives.

Fan Engagement and Club Heritage

The framework requires meaningful supporter engagement and protects important elements of club identity. Changes involving club names, crests, predominant home shirt colours and home grounds may trigger consultation, consent or regulatory approval requirements, depending on the proposal.

Clubs should identify these requirements before decisions progress and retain evidence of the engagement undertaken.

Regulatory Notifications and Ongoing Compliance

The IFR’s additional duties are now live, although individual obligations arise only where the relevant circumstances occur. These include duties concerning material changes to club circumstances, administration and insolvency, home grounds, club identity and prohibited competitions.

Clubs need processes that identify relevant events, assign responsibility and escalate matters promptly. The IFR has information-gathering and enforcement powers to investigate and address breaches, making accurate records and timely regulatory responses essential.

Club considerations

Clubs should review their existing arrangements against the published framework and prioritise the work needed to:

Identify obligations already in force and the circumstances that trigger them
Assess provisional licensing readiness and gaps in supporting evidence
Review financial planning, risk management and Board reporting
Map ownership, Senior Management roles and appointment processes
Establish effective fan engagement and heritage decision procedures
Assign responsibility for regulatory notifications and recurring obligations
Create a prioritised remediation plan with clear owners and deadlines

The review should consider the club’s circumstances and the requirements applicable to it. Starting early gives Boards and Senior Management time to address weaknesses and prepare reliable submissions.

How Complyport Can Help

Complyport provides specialist football regulatory compliance and governance support to clubs, Boards, owners and Senior Management.

Our specialists can assist with:

IFR Readiness and Licensing, including application preparation and evidence reviews;
IFR Regulatory Readiness and Governance Assessments, identifying gaps and prioritising remediation;
Financial Resilience and Prudential Governance, reviewing forecasting, liquidity, funding and financial risk oversight;
Owners, Directors and Senior Executives Regime Support, including suitability processes, appointments and notifications;
Board and Senior Management Training on regulatory responsibilities; and
Ongoing IFR Compliance and Assurance, including regulatory monitoring, control testing, reporting and remediation oversight.