The Independent Football Regulator is undertaking an extremely important consultation process which closes on Monday the 6th of October 2025. The consultation process is open to (among others) all football fans.

If we (as fans) want to shape our game, then it is, in my opinion, vital that we participate at every opportunity we get.

Many of the answers to questions that fans may have about this process can be found here

Background

The Football Governance Act 2025 (the Act) received Royal Assent on 21 July, 2025. The Act establishes the Independent Football Regulator (the IFR).

The IFR’s core statutory objectives are to:

• protect and promote the financial soundness of regulated clubs

• protect and promote financial resilience of English football

• safeguard the heritage of English football

The IFR will have powers to operate a licensing regime, and to monitor and enforce compliance with requirements on financial regulation; fan engagement; club heritage; and will introduce an enhanced club owners, directors and senior executives test (ODSE).

The IFR will set corporate governance standards, will oversee a number of obligations on clubs protecting club heritage, e.g. stadia sales, changes to badges and kit colours, and will have the power to prohibit regulated clubs from joining competitions where they are not fair and meritocratic, and would threaten the heritage and sustainability of English football.

Establishing the IFR is expected to be complete in the autumn, when the organisation is scheduled to have an independent Board comprising Executive and Non-executive Directors, a Chair and a Chief Executive Officer.

The Consultation:

This consultation sets out how the IFR proposes to establish and oversee the Owners, Directors & Senior Executives (ODSE) regime set out in Part 4 of the Act.

The Act requires the IFR to assess the suitability of incoming owners of regulated clubs, and the key senior individuals that direct and run them. The Act also provides the IFR with the powers to consider the suitability of incumbent owners and key senior individuals.

For this purpose, the IFR is consulting on the following documents:

• IFR Draft ODSE Rules for clubs, owners, senior managers and others engaging with the ODSE Regime

• IFR Draft ODSE Guidance which explains how the regime will operate and what clubs, owners, officers and others can expect from the IFR

• Draft application forms for owners and senior managers seeking approvals from the IFR

The IFR is preparing and consulting on these proposals under section 12 of the Act.

The consolidated consultation document can be accessed here: ODSE Consultation paper

The Act requires the IFR to conduct assessments under the ODSE regime against a specific test. The tests are more onerous than the previous “fit and proper owner” tests. The IFR may only approve an application by an individual to become a new owner of a regulated club where the individual meets the following criteria:

(i) having the requisite honesty and integrity,  (ii) having the requisite competence and (iii) being financially sound

and the IFR:
o considers that the prospective owner has sufficient financial resources; and
o does not have grounds to suspect that the individual has any source of wealth which is connected to serious criminal conduct.

I will attempt to expand on the above in the coming days.

Additional relevant documents:

The Football Governance Act 2025

The Fan Led Review of Football Governance

White Paper: A Sustainable Future – reforming club football governance

Beyond the ODSE consultation, there are the following further consultations, again with an October 6th 2025 cut off date.

Information Gathering and Enforcement Questions

Sanctions Guidance

I will try and add to the above in the coming days – this is just my initial flagging of something that’s crucial in terms of keeping fans part of this process.