The Analysis Series: The Independent Football Regulator and its likely Impact on English Football

The Football Governance Act 2025  which received Royal Assent on 21 July 2025, marks the end of the era of the football industry’s self-regulation and establishes a new statutory body, the Independent Football Regulator (IFR). 

This analysis  looks at the new regulatory framework, its legislative underpinnings, the structure and powers of the IFR, and its anticipated impact on the Premier League, the English Football League (EFL), the National League, and individual clubs.

The creation of the IFR is the culmination of years of mounting concern over poor governance. This is evidenced by systemic financial instability, a series of high-profile club collapses, and severe governance failures, which were brought to a head by the attempted formation of a breakaway European Super League in 2021. The subsequent Fan-Led Review of Football Governance provided the blueprint for the Act, which tasks the IFR with three core objectives: 

• Ensuring the financial soundness of individual clubs, 
• Promoting the systemic financial resilience of the football pyramid
• Safeguarding the heritage of English football

The IFR will be an independent public body, led by a Chair and CEO, funded by a levy on the 116 clubs in the top five tiers of the men’s game that fall within its remit. 

Its primary tool will be a mandatory licensing regime, requiring all clubs to obtain either a provisional or full licence to compete. This regime is underpinned by a suite of new regulatory tools, including a strengthened statutory Owners’ and Directors’ Test, 

This introduces a new ‘competence’ assessment for directors; robust powers to protect club heritage, such as requiring majority fan support for changes to crests and home shirt colours; a prohibition on joining breakaway leagues; and, most contentiously, a backstop mechanism to impose a financial distribution settlement between the leagues if they fail to reach an agreement themselves.

For the Premier League, the Act introduces an era of external oversight, with concerns remaining about the potential for “unintended consequences” that could impact its global competitiveness. For the EFL and National League, the legislation is viewed as a watershed moment and a generational opportunity to address the destabilising financial chasm between the top flight and the rest of the pyramid.

At the individual club level, the operational and financial impacts will be significant. Clubs face substantial new compliance burdens, with government estimates projecting ongoing annual compliance costs of between £17.9 million and £35.8 million across the 116 clubs, plus the levy required to fund the IFR’s operations. 

The Act elevates regulatory risk as a key strategic consideration for owners and investors, requiring a comprehensive overhaul of corporate governance, financial planning, and fan engagement strategies.

I will look at how clubs might navigate this new reality, emphasising the need for immediate gap analysis, the formalisation of fan engagement structures, and the integration of regulatory compliance into all core business functions.

 The Case for Change

The establishment of a statutory regulator for English football represents a monumental shift, moving the governance of the national sport from a model of delegated self-regulation, managed by the leagues and the Football Association (FA), to one of direct, independent oversight by a public body. 

The move to an independent regulator was not a sudden development but the culmination of decades of systemic financial and governance failures that progressively eroded confidence in the industry’s ability to regulate itself.

For years, the governance of English football has been beset by a series of crises that highlighted deep-seated structural flaws. The primary catalyst for reform has been the issue of financial mismanagement, which has led to a procession of historic clubs facing insolvency and, in some cases, extinction.  What is happening at Morecambe Town, the financial collapses of Bury FC and Macclesfield Town, along with the well-documented financial traumas at clubs such as Bolton Wanderers, Derby County, Wigan Athletic, and Reading, created an irrefutable body of evidence that the existing regulatory framework was failing in its most basic duty: to protect the existence of community clubs. 

These events demonstrated that over-ambitious, incompetent, or duplicitous owners could operate with impunity, lie about their funding capabilities and management expertise, first leveraging clubs with unsustainable debt and ultimately leaving fans and local communities to suffer the consequences when owner funding was inevitably withdrawn or was never available in the first instance.

While these individual club crises built the case for change over time, the final, decisive event that made government intervention politically unavoidable was the attempted formation of a breakaway European Super League in April 2021

 The plan, involving six of England’s biggest clubs, exposed the complete non-alignment between the commercial ambitions of a small ownership elite and the foundational principles of sporting merit and open competition that underpin the English football pyramid. 

The universal condemnation of the project, led by a unified and powerful fan backlash, demonstrated the deep cultural significance of football clubs and forced the government to act.

In response, the government commissioned the Fan-Led Review of Football Governance, chaired by former sports minister Tracey Crouch. Published in late 2021, the review’s report was a forensic examination of the game’s failings and provided a comprehensive blueprint for reform. Its central recommendation—the establishment of an independent regulator for English football by an Act of Parliament—became the cornerstone of the government’s policy.

 The review’s other key proposals, including the need for a strengthened owners’ and directors’ test, robust financial controls, greater fan engagement, and the protection of club heritage, are all directly reflected in the final legislation.

The Stated Purpose of the Football Governance Act 2025

The legislative vehicle for this new era of governance is the Football Governance Act 2025, which received Royal Assent on 21 July 2025, formally establishing it as law. The Act’s long title clearly states its purpose:

 “to establish the Independent Football Regulator; to make provision for the licensing of football clubs; to make provision about the distribution of revenue received by organisers of football competitions; and for connected purposes”.

The Act defines its overarching purpose as being “to protect and promote the sustainability of English football”. Critically, it further defines a sustainable English football ecosystem as one that “continues to serve the interests of fans” and “continues to contribute to the economic or social well-being of the local communities with which regulated clubs are associated”.

 This language is significant, as it codifies a huge shift in how football clubs are viewed in law. 

Traditionally, under corporate law, a company is a private commercial entity accountable primarily to its shareholders. The historical governance of football has mirrored this, with leagues acting as associations of their member clubs. 

However, by explicitly naming fans and local communities as primary beneficiaries of the regulatory framework, the Act legally elevates their interests. Powers that require fan consent for heritage changes or IFR approval for stadium sales legally subordinate the principle of shareholder primacy to the preservation of the club as a community and cultural asset. 

This imposes a legally enforceable duty of stewardship on owners that extends beyond mere profit-making, fundamentally redefining a football club’s legal and social obligations.

To achieve its purpose, the Act establishes the IFR and endows it with three primary statutory objectives:

1. The Club Financial Soundness Objective: To protect and promote the financial soundness of individual regulated clubs, ensuring they are run sustainably.
2. The Systemic Financial Resilience Objective: To protect and promote the financial resilience of English football as a whole, addressing systemic risks like the distribution of revenue through the pyramid.
3. The Heritage Objective: To safeguard the heritage of English football, recognising that clubs are vital cultural assets for their communities.

These three objectives form the legal mandate upon which all of the IFR’s powers and functions are based.

The Independent Football Regulator (IFR)

The Football Governance Act 2025 creates the IFR as the central authority in the new regulatory landscape. Its structure, leadership, and operational philosophy are designed to ensure its independence and effectiveness while being mindful of the unique commercial and cultural context of English football.

Corporate Structure and Governance

The IFR is established as a new, independent public body, designed to operate at arm’s length from both the UK government and the existing football authorities (the FA, Premier League, and EFL). This structural independence is a core principle of the reform, intended to eliminate the conflicts of interest inherent in a self-regulatory model where clubs effectively regulate themselves.

The regulator’s governance structure will be led by a Chair, a full-time Chief Executive Officer (CEO), and a Board comprising several non-executive directors. The Secretary of State for Culture, Media and Sport is responsible for appointing the Chair and the non-executive directors, following a public appointments process. The Chair, in turn, will lead the recruitment of the CEO, who will be responsible for the day-to-day running of the organisation.

A key feature of the IFR’s structure is the creation of an Expert Panel. This body of independent experts will have two primary functions: to conduct internal reviews of certain IFR decisions when requested by an affected party, and, most significantly, to act as the ultimate arbiter in financial distribution disputes between the leagues should the backstop mechanism be fully triggered.

To maintain its independence, the Act stipulates that leagues and clubs will have no formal representation on the IFR’s Board. However, in recognition of its status as the national governing body for the sport, the Football Association (FA) will be entitled to have an observer on the Board.

The IFR’s operations will be funded through a statutory levy imposed on all clubs within its scope, which covers the 116 clubs in the top five tiers of the men’s English football pyramid.

 While initial funding will come from the Exchequer, the regulator will transition to this industry-funded model. The Act allows for the levy to be set at different levels for different clubs, indicating that it will be applied proportionately, likely based on a club’s revenue or league status.

Leadership and Executive Authority: The Appointment of David Kogan

On 25 April 2025, the government announced that its preferred candidate for the inaugural Chair of the IFR was David Kogan OBE. Kogan brings a 45-year career as a high-profile media executive and corporate advisor, with extensive experience in the business of football. He is best known for negotiating a succession of multi-billion-pound television rights deals on behalf of major sporting bodies, including the Premier League, the EFL, the Women’s Super League, UEFA, and the Scottish Premier League.

The appointment has not been without controversy. Some EFL clubs have expressed concern over Kogan’s historical proximity to the Premier League, having worked closely with its former CEO Richard Scudamore for many years.

 Furthermore, the appointment drew accusations of political “cronyism” from opposition MPs following the disclosure of Kogan’s financial donations to the Labour Party, including to the Prime Minister and the Culture Secretary. These concerns ultimately led the independent Commissioner for Public Appointments to launch a full inquiry into the appointment process to determine if all rules were followed. Despite this, Kogan’s appointment was endorsed by the cross-party Culture, Media and Sport Select Committee following a pre-appointment scrutiny hearing.

Kogan’s role as Chair is a part-time position, remunerated at £130,000 per annum for a commitment of three days per week. His primary initial responsibilities include overseeing the establishment of the regulator and appointing a full-time CEO, who is expected to have a background in financial regulation and will manage the IFR’s day-to-day operations. 

To lead the initial setup phase, Martyn Henderson OBE was appointed as the interim Chief Operating Officer of the shadow regulator in late 2023. The process of appointing the permanent CEO and the full board of non-executive directors is ongoing and will be completed following the IFR’s formal launch.

Operational Remit and Guiding Principles

The Act is explicit that the IFR’s remit is strictly limited to off-pitch matters. It will have no role in sporting rules, on-field decisions, or the micromanagement of clubs’ commercial strategies.Its focus is squarely on financial sustainability, corporate governance, and heritage protection.

In exercising its functions, the IFR is bound by a set of statutory regulatory principles designed to ensure its approach is balanced and appropriate for the football context. These principles include:

• Proportionality: Any intervention or requirement must be tailored to a club’s specific circumstances and the risks it faces, avoiding unnecessary burdens on well-run or low-risk clubs.
• Participation: The IFR must proactively and constructively engage with the industry, including clubs, leagues, owners, and fans.
• Transparency: The regulator must act as transparently as is reasonably practicable.

The IFR is also mandated to adopt an “advocacy-first” approach to enforcement. This means it will aim to work collaboratively with clubs to achieve compliance through guidance and support before resorting to its formal sanctioning powers. These powers will be reserved for more serious or persistent cases of non-compliance.

Of critical importance is the IFR’s secondary duty outlined in the Act. While pursuing its three primary objectives, the IFR must, so far as is reasonably practicable, exercise its functions in a way that avoids adverse impacts on the sporting competitiveness of English clubs (including against international rivals), and on financial investment in and the growth of English football.

 This clause reveals a core tension at the heart of the legislation: the need for robust, independent intervention to ensure sustainability versus the political and economic imperative to not harm the commercial success of the Premier League, often described as English football’s golden goose. 

The Premier League has consistently voiced concerns that “rigid banking-style regulation” could damage its global appeal. This secondary duty seeks to provide a legislative safeguard against regulatory overreach and will be a key battleground in future debates between the IFR and the top flight. 

Every major decision the IFR makes will involve a delicate balancing act between its primary sustainability objectives and this secondary duty to protect the league’s commercial engine. The appointment of a commercial heavyweight like David Kogan, rather than a pure financial regulator, suggests the government prioritises the ability to navigate this complex commercial-regulatory dynamic above all else.

What are the IFR’s Powers?

The Football Governance Act 2025 equips the IFR with powers designed to address the key areas of failure identified by the Fan-Led Review. These powers are interconnected, aiming to form a holistic regulatory system centred on a mandatory licensing regime.

The Licensing Regime

The cornerstone of the IFR’s authority is a new statutory licensing system. It will be unlawful for a club to operate a team in the top five tiers of men’s English football—the Premier League, Championship, League One, League Two, and the National League—without a licence granted by the IFR.

 This represents a fundamental shift, as participation will no longer be solely at the discretion of the leagues but will be conditional on meeting statutory standards of governance and financial health.

The Act establishes a two-stage licensing process:

1. Provisional Licence: Upon the regime coming into force, all clubs will need to apply for a provisional licence. This will be granted for an initial period of up to three years. To obtain it, clubs must submit foundational documentation, including a strategic business plan with financial forecasts and a detailed personnel statement identifying all owners and senior officers. They must also demonstrate that they are ready, willing, and able to comply with a set of core, baseline requirements.
2. Full Licence: Before the provisional period expires, the IFR will proactively assess each club for a full operating licence. This is a more stringent test. To be granted a full licence, a club must demonstrate that it meets three higher, club-specific “Threshold Requirements”:

• Appropriate Financial Resources: The club must have the financial means to meet its cash flows, even in the event of a financial shock, and must protect its core assets like the stadium.
• Appropriate Non-Financial Resources: The club must have adequate internal structures, policies, and personnel for functions such as risk management.
• Adequate Fan Engagement: The club must have a framework for regularly and effectively consulting fans on key strategic and heritage matters.

A significant feature designed to reduce the administrative load on clubs is that, once a full licence is granted, it will not need to be periodically renewed. Instead, the IFR will engage in ongoing, real-time monitoring. If it identifies that a club’s standards are slipping or that new risks have emerged, it has the power to intervene by placing bespoke discretionary licence conditions on that specific club to bring it back up to the required threshold.

Scrutinising Owners and Directors

The Act introduces a new, strengthened statutory Owners’ and Directors’ Test, replacing the separate tests previously administered by the individual leagues.

 This new test is designed to be more comprehensive and proactive, aiming to ensure that only suitable custodians can own and run English football clubs.

The test for prospective new owners comprises three distinct elements:

1. A Fitness Test: This assesses an individual’s honesty, integrity, and financial soundness.
2. A Source of Wealth Test: This requires prospective owners to provide evidence of the ultimate source of their funding, a measure designed to mitigate the risk of illicit finance entering the game.
3. A Financial Plans and Resources Test: Prospective owners must submit a detailed business plan for the club and provide evidence that they have sufficient financial resources to fund it sustainably.

The test for prospective new directors and other senior officers includes the fitness test (honesty, integrity, and financial soundness), but also introduces a groundbreaking new criterion: competence. For the first time, the suitability of a director will be formally assessed based on their qualifications, experience, and training.

 This particular requirement is poised to professionalise club boardrooms. Historically, directorships have often been filled based on wealth or personal relationships with an owner, rather than specific professional expertise. The existing tests focused on a checklist of disqualifying conditions, such as criminal convictions, not on positive attributes.

 By mandating an assessment of competence, the Act will compel clubs to justify board appointments on the basis of demonstrable professional merit. This will likely drive demand for directors with formal qualifications in finance, law, and corporate governance, shifting the boardroom from a collection of interested parties to a body of qualified fiduciaries accountable for sound decision-making.

Incumbent owners and directors will not be automatically re-tested when the regime begins. However, the IFR is granted the power to test an incumbent individual at any time if it has “grounds for concern” about their suitability, which could be triggered by a material change in their circumstances.

The IFR is equipped with a range of powerful enforcement tools to deal with individuals who fail the test. These include the power to issue disqualification orders, preventing an individual from being an owner or director of any regulated club, and, in the most serious cases, ownership removal orders, which can ultimately force an unsuitable owner to divest their shareholding in a club.

The following table provides a comparative analysis of the new statutory test against the previous regime administered by the leagues.

Table 1: Comparative Analysis of Owners’ and Directors’ Tests

Financial Fair Play 

The Act empowers the IFR to introduce “targeted, forward-looking financial sustainability regulation”.

This will move beyond the existing profit and sustainability rules, requiring clubs to demonstrate sound basic financial practices, maintain appropriate financial resources to withstand shocks, and protect core assets like their stadium.

However, the most powerful and politically contentious tool in the IFR’s financial arsenal is the financial distribution backstop mechanism. 

This gives the IFR the power to intervene and impose a financial settlement on the distribution of revenue between the leagues as a last resort, should the leagues fail to negotiate an agreement themselves. This power addresses the long-running dispute between the Premier League and the EFL over how broadcast revenue should be shared across the pyramid. The amended version of the Bill explicitly includes controversial

parachute payments—large sums paid to clubs relegated from the Premier League—within the scope of revenues the IFR can consider in a settlement, a key demand of the EFL.

The process for invoking and executing this backstop power is meticulously defined in the Act, as detailed in the flowchart below.

Table 2: The Financial Distribution Backstop Mechanism – A Step-by-Step Process

Heritage, Fan Engagement, and Breakaway Leagues

A central pillar of the Act is the statutory protection of club heritage, recognising that clubs are more than just businesses. The IFR is given strong powers to enforce these protections:

• Club Crest and Colours: Clubs will be legally required to take reasonable steps to establish that any material changes to their club crest or predominant home shirt colours are supported by a majority of their fans in England and Wales. Any change to a club’s name requires the prior approval of the FA, which has its own rules mandating fan consultation.
• Stadium Protection: Clubs must seek IFR pre-approval before selling their home ground or relocating to a new one. The IFR will only grant approval if it is satisfied that the move would not undermine the financial sustainability of the club.
• Fan Engagement: Meaningful fan engagement is a mandatory condition of the licensing regime. Clubs will be required to consult regularly with a representative group of their supporters (such as a Fan Advisory Board or Supporters’ Trust) on key strategic matters, including the club’s business priorities, operational issues like ticket pricing, and all matters of club heritage.
• Prohibition of Breakaway Leagues: The Act gives the IFR the power to prohibit English clubs from joining competitions that are not based on sporting merit, threaten the sustainability of existing domestic competitions, or harm the heritage of English football. This power is a direct response to the European Super League threat and effectively makes it illegal for English clubs to join such a competition without IFR approval.

A New Operational Reality for English Clubs

The introduction of the IFR and the enforcement of the Football Governance Act 2025 will have profound and wide-ranging impacts on all stakeholders in English football. The new regulatory framework creates a fundamentally different operational and financial environment, requiring strategic adaptation from the wealthiest Premier League clubs to those in the National League.

 The Premier League:

For the Premier League, the Act represents the end of an era of relative autonomy and the beginning of a new relationship with an independent statutory overseer. 

While the league has publicly stated its commitment to working constructively with the IFR, it has also consistently voiced significant concerns. The primary apprehension is that “unintended consequences” and “rigid banking-style regulation” could damage the league’s commercial success, which it argues is vital for funding the entire football pyramid.

Premier League Chief Executive Richard Masters has publicly questioned the parallels drawn between football and the banking system, advocating for a “light touch, proportionate regulation”.

The most direct financial impact on the Premier League will likely stem from the financial distribution backstop mechanism. The very existence of this power shifts the negotiating balance in favour of the EFL. The threat of the IFR imposing a settlement will increase the pressure on the Premier League to agree to a more generous revenue-sharing deal than it might have otherwise offered, particularly as the regulator’s remit now explicitly includes parachute payments.

In its engagement with the IFR, the Premier League is expected to heavily leverage the regulator’s secondary statutory duty to avoid adverse impacts on sporting competitiveness and financial investment. This clause will serve as the league’s primary defence against any regulatory measures it deems overly restrictive or damaging to its global brand and appeal.

 The EFL and National League: 

In stark contrast to the Premier League’s cautious stance, the EFL has championed the legislation. 

EFL Chair Rick Parry has hailed the Act as a “watershed moment” essential for fixing a “broken financial model”. The EFL’s position is rooted in the dire financial reality faced by many of its member clubs. In written evidence to Parliament, the league stated that its clubs were collectively expected to lose around £450 million in a single season, with the majority of clubs being technically insolvent and reliant on continuous owner funding to survive.

From the perspective of the EFL and the National League, the Act’s most critical component is the potential for a rebalanced financial distribution. 

The backstop mechanism is viewed as a once-in-a-generation opportunity to address what Parry describes as the “destabilising, ever widening, and deeply unfair” distribution of revenues. The hope is that a fairer settlement, whether negotiated under the shadow of the IFR’s power or imposed by it, will create a more sustainable pyramid, allowing clubs to “rise and fall… without the threat of financial catastrophe”.

 The IFR’s first State of the Game report, which should provide an objective analysis of the game’s finances, is seen as a crucial evidence base that will guide the regulator towards this objective.

The Club Level: Compliance Burdens, Governance Overhauls, and Strategic Shifts

For individual clubs across all five regulated tiers, the Act introduces a new and demanding operational reality.

Operational Impact: Clubs will be required to implement significant changes to their internal governance and administrative processes. This includes:

• Developing robust, forward-looking financial plans and corporate governance statements to satisfy the conditions of the licensing regime.
• Establishing formal and effective fan consultation frameworks, such as Fan Advisory Boards, to meet the mandatory fan engagement requirements.
• Creating new internal approval processes to ensure that any decisions related to club heritage (crests, colours) or key assets (stadiums) are compliant with the Act and, where necessary, submitted for IFR or fan approval.

Financial Impact (Compliance Costs): The direct financial costs of compliance will be substantial. The government’s official Impact Assessment provides a stark projection of the new financial burden that will be borne by the 116 regulated clubs:

• Familiarisation Costs: A one-off cost, incurred in the first year, estimated to be between £400,000 and £1.2 million in total for all clubs.
• Ongoing Compliance Costs: An annual recurring cost for all clubs, estimated (by Government) to be between £17.9 million and £35.8 million.
• IFR Levy: In addition to their own compliance costs, clubs will be required to fund the IFR’s annual operational costs, estimated at between £77.4 million and £106.8 million, through a statutory levy.

While the Act mandates a proportionate approach, these universal requirements introduce a new dynamic. A large Premier League club with a dedicated in-house legal and finance department can absorb these administrative and financial burdens with relative ease. 

However, for a smaller National League club with a skeleton administrative staff, the same requirements represent a far greater proportional burden. The cost of hiring external consultants or new permanent staff to manage IFR compliance could divert a significant percentage of a smaller club’s resources away from on-pitch investment.

 This creates the potential for a new form of inequality, where larger clubs can navigate the complex regulatory landscape more efficiently, potentially widening the operational gap even as the Act aims to narrow the financial one.

Strategic Impact: The most fundamental change for club owners and executives is the introduction of a new, dominant form of regulatory risk. Strategic decision-making can no longer be based solely on financial and sporting considerations. Every major decision—from transfer spending and wage structures to infrastructure projects and ownership changes—must now be stress-tested against the IFR’s financial sustainability and governance requirements.

 This will have a profound effect on the due diligence process for prospective investors, who must now assess a target club’s regulatory health and compliance status as a primary component of its valuation and risk profile.

 Conclusion and Strategic Recommendations

The Football Governance Act 2025 is the most significant intervention in the governance of English football in its history. It marks a definitive end to the era of self-regulation and ushers in a new system of statutory oversight designed to address the deep-seated issues of financial instability and poor governance that have long plagued the national sport.

The Long-Term Vision for English Football

The Act represents a fundamental redefinition of the role and responsibilities of a professional football club. It moves beyond the traditional view of clubs as purely private commercial enterprises and legally enshrines their status as vital community and cultural assets. 

By creating the Independent Football Regulator, the legislation establishes a new balance of power, elevating the principles of long-term financial sustainability, fan engagement, and heritage protection to a level of importance on par with commercial growth and on-field success.

The IFR has been equipped with a formidable array of powers, from a mandatory licensing regime and a strengthened owners’ and directors’ test to the ability to block participation in breakaway leagues and, as a last resort, impose a financial settlement on the entire pyramid. However, its mandate is also carefully balanced. The statutory duty to avoid harming the competitiveness and investment appeal of English football acknowledges the immense economic and cultural value of the Premier League’s global success. The long-term success of this new regulatory era, and of its inaugural Chair, David Kogan, will be determined by the IFR’s ability to skilfully navigate this inherent tension—enforcing discipline and sustainability without stifling the dynamism and ambition that makes English football so compelling.

Strategic Recommendations for Club Executives and Owners

For the 116 clubs now under the IFR’s remit, proactive and strategic adaptation is not optional; it is essential for securing their licence to operate and for thriving in the new regulatory environment. The following recommendations provide a roadmap for club executives, directors, and owners to prepare for the changes ahead.

Immediate Actions (First 6-12 Months):

1. Conduct a Comprehensive Gap Analysis: Clubs should immediately commission an internal review to assess their current operational practices against the known requirements of the Football Governance Act. This analysis should cover financial planning and reporting, corporate governance structures, existing fan engagement mechanisms, and policies related to club heritage. The output should be a clear report identifying all areas of non-compliance or potential weakness.
2. Establish a Formal Fan Advisory Board (FAB): Proactively establishing a structured, representative, and democratic fan engagement body is the single most effective step a club can take to meet the fan consultation conditions of the licence. This should be done in genuine partnership with existing supporters’ trusts and groups.
3. Review Board Composition and Competence: The board of directors should be reviewed in light of the new ‘competence’ criterion in the Owners’ and Directors’ Test. Clubs must assess whether their current directors possess the requisite qualifications, experience, and training, particularly in areas of finance and risk management, and begin succession planning if gaps are identified.

Medium-Term Strategy (1-3 Years):

1. Budget for Compliance and the IFR Levy: Clubs must integrate the projected financial costs of the new regime into their medium-term financial plans. This includes budgeting for increased administrative headcount or external advisory fees for compliance, as well as forecasting the annual cost of the IFR levy.
2. Integrate Regulatory Risk into Core Strategy: Regulatory risk must be elevated to a primary strategic concern. The IFR’s requirements should be embedded into the club’s central risk register, and all major financial and operational decisions—from player acquisitions to capital projects—should be formally assessed through a regulatory compliance lens.

Long-Term Outlook:

1. Foster a Culture of Proactive Engagement: Clubs should adopt a policy of open, transparent, and constructive engagement with the IFR. Given the regulator’s “participative” and “advocacy-first” principles, a cooperative approach is more likely to yield positive regulatory outcomes than a confrontational one. Building a strong working relationship with the regulator should be a key objective for club leadership.

Final Personal conclusions:

The IFR should be viewed as a tremendous opportunity to improve governance across football. As I have always contested, improved governance leads to better qualified people, with better, clearer motives, making better decisions.

The IFR will not solve all the inequities of modern football, they are firmly baked in. It should however, provide greater protections against the appalling mismanagement of individual clubs (and its consequences) and create distance between the regulators and promoters of professional football, something that the Premier League in particular was never able to achieve, largely because of its inadequate founding structures.