A precise, section-by-section analysis
Sourced exclusively from the text of the Football Governance Act 2025 (c. 21)
This report sets out, precisely and by direct reference to the statutory text, the duties of the Independent Football Regulator (the IFR) under the Football Governance Act 2025 (c. 21) with regard to protecting the game of professional football. It is drawn exclusively from the Act itself. Every substantive claim is referenced to the specific section, subsection or Schedule from which it derives.
The Act establishes the IFR as a body corporate (section 5) and gives it a statutory purpose that frames every duty that follows: ‘to protect and promote the sustainability of English football’ (section 1(1)).
Section 1(3) defines sustainability narrowly and precisely: English football is sustainable if it (a) continues to serve the interests of fans of regulated clubs, and (b) continues to contribute to the economic or social well-being of the local communities with which regulated clubs are associated. Every other duty in the Act is to be read as an instrument for achieving that statutory purpose.
The IFR’s protective function is then operationalised through three statutory objectives (section 6): the club financial soundness objective, the systemic financial resilience objective, and the heritage objective.
Sections 7 and 8 impose general duties and regulatory principles governing how those objectives must be pursued. The remainder of the Act, licensing (Part 3), ownership and officer suitability (Part 4), specific duties on clubs and competition organisers (Part 5), the revenue distribution mechanism (Part 6), and information, investigation and enforcement powers (Parts 7 and 8), gives the IFR the specific statutory tools through which those three objectives, and the underlying duty to protect sustainability, are to be discharged.
| Statutory purpose | To protect and promote the sustainability of English football (s.1(1)) |
| Sustainability defined | Serving fan interests and contributing to economic/social well-being of local communities (s.1(3)) |
| Three statutory objectives | Club financial soundness; systemic financial resilience; heritage (s.6) |
| General duty | Exercise functions, so far as reasonably practicable, compatibly with the purpose and advancing one or more objectives (s.7(1)) |
| Eight regulatory principles | Efficiency; cooperation; necessity/proportionality; proportionality of restrictions; football-context sensitivity; consistency; recognition of owner/officer responsibility; transparency (s.8) |
| Principal protective mechanisms | Operating licences (Part 3); owner/officer suitability regime (Part 4); specific duties on clubs (Part 5); revenue distribution resolution process (Part 6) |
Statutory purpose and the meaning of “protection”
Section 1(1) of the Act provides: “The purpose of this Act is to protect and promote the sustainability of English football.”
This is not an aspirational recital; it is the express interpretive anchor for the entire statute, and section 7(1)(a) requires the IFR, so far as reasonably practicable, to exercise every one of its functions in a way that is compatible with this purpose.
Football Governance Act 2025, s.1(1)
Section 1(2) lists the structural means by which the Act pursues that purpose:
- the establishment of the IFR and provision about the exercise of its functions (Part 2);
- operating licences (Part 3);
- determinations on the suitability of owners and officers (Part 4);
- duties imposed on clubs, owners, officers and competition organisers (Part 5);
- the revenue-distribution order mechanism (Part 6);
- investigation and enforcement powers (Parts 7 and 8);
- review and appeal provisions (Part 9);
- and general provisions including information disclosure (Part 10).
Football Governance Act 2025, s.1(2)(a)-(h)
Critically, section 1(3) gives “sustainability”, and therefore the entire concept of statutory “protection” under the Act, a precise, two-limbed definition. English football is sustainable, for the purposes of the Act, only if it:
| Statutory text | |
| continues to serve the interests of fans of regulated clubs | |
| continues to contribute to the economic or social well-being of the local communities with which regulated clubs are associated |
Football Governance Act 2025, s.1(3)(a)-(b)
This definition is significant for precision: the Act does not define “protecting football” by reference to competitive integrity, the quality of the on-field product, or commercial success. Protection under the Act is defined entirely in terms of service to fans and contribution to local communities. Any analysis of the IFR’s protective duties must be read through this specific statutory lens.
The three statutory objectives (Section 6)
Section 6 sets out the IFR’s objectives in full:
“The IFR’s objectives are:
(a) to protect and promote the financial soundness of regulated clubs (referred to in this Act as ‘the club financial soundness objective’);
(b) to protect and promote the financial resilience of English football (referred to in this Act as ‘the systemic financial resilience objective’);
(c) to safeguard the heritage of English football (referred to in this Act as ‘the heritage objective’).”
Football Governance Act 2025, s.6(a)-(c)
The club financial soundness objective
This objective operates at the level of the individual regulated club. It is given operative effect principally through the licensing regime (Part 3) and, in particular, the “financial resources threshold requirement” in Schedule 4, paragraph 2: this requirement is met, in relation to a club, “if the financial resources of the club are appropriate in relation to the activities the club carries on or seeks to carry on.” In assessing this, the IFR may have regard to the club’s corporate structure (including any group of which it forms part), its latest financial plan and the risks identified in it, its strategic business plan, the competition(s) in which it operates a team, and its non-financial resources.
Football Governance Act 2025, Sch.4 para.2(1)-(2)
The systemic financial resilience objective
This objective operates at the level of the football pyramid as a whole, distinguishing it from the club-level financial soundness objective. It is given direct effect through section 22(3), which permits the IFR to attach a discretionary licence condition for the specific purpose of advancing the systemic financial resilience objective, restricted to matters of debt management, liquidity requirements, or restricting a club’s overall expenditure (but not restricting expenditure of a particular kind or a particular transaction: section 22(4)).
Football Governance Act 2025, s.22(3)-(4)
The systemic objective is also embedded in the Part 6 revenue-distribution mechanism: under section 59(2)(b), the IFR may only trigger the resolution process between competition organisers where it “has reasonable grounds to suspect that its ability to advance at least one of its objectives would be jeopardised” if the process were not triggered, directly connecting inter-league financial distribution to the systemic resilience of the game as a whole.
Football Governance Act 2025, s.59(2)(b)
The heritage objective
This objective is given the most granular and specific statutory protection of the three, through a discrete set of duties in Part 5 of the Act that directly restrain clubs from unilaterally altering matters fans regard as fundamental to a club’s identity:
| Provision | Statutory mechanism | Subject matter |
| Home ground (s.46) | A club must notify the IFR and obtain its approval before disposing of any interest in its home ground, or using it as loan security. The IFR must grant approval only if satisfied the step would not undermine the club’s financial sustainability (or, for a formerly regulated club, that all reasonable steps have been taken to ensure a team continues to play there). | Disposal / security over ground |
| Relocation (s.48) | A club must notify the IFR and obtain approval before entering arrangements to play home matches elsewhere. Approval may be granted only if the IFR is satisfied the move would not undermine financial sustainability, would not cause significant harm to the club’s heritage, and the club has consulted its fans and had regard to their views. | Stadium relocation |
| Crest, colours, name (s.49) | A club must not make material changes to its crest or emblem, or to its predominant home shirt colours, unless it has taken reasonable steps to establish majority fan support. A club must not change a team’s name without Football Association approval. | Identity / branding |
Football Governance Act 2025, ss.46, 48, 49
Schedule 4, paragraph 4(3) further defines “heritage” matters for the purposes of the fan engagement threshold requirement as expressly including the club’s home ground, any emblem or crest, predominant home shirt colours, and the name of any relevant team, giving the heritage objective a precise statutory content rather than leaving it undefined.
Football Governance Act 2025, Sch.4 para.4(3)(a)-(d)
The general duties governing the exercise of protective functions (Section 7)
Section 7(1) imposes the IFR’s core general duty: “The IFR must, so far as reasonably practicable, exercise its functions under this Act in a way that (a) is compatible with the purpose of this Act…, and (b) advances one or more of the IFR’s objectives.”
This duty applies to every function the IFR exercises under the Act, and binds the exercise of protective powers specifically to both the overarching sustainability purpose and the three section 6 objectives.
Football Governance Act 2025, s.7(1)(a)-(b)
Section 7(2) qualifies how the IFR must pursue that protective duty by requiring it to have regard to the desirability of avoiding three specific categories of harm when exercising its functions:
| s.7(2)(a) | effects on the sporting competitiveness of any regulated club against another regulated club |
| s.7(2)(b) | adverse effects on the competitiveness of regulated clubs against other (i.e. non-regulated, including overseas) clubs |
| s.7(2)(c) | adverse effects on the financial growth of, or financial investment in, English football |
Football Governance Act 2025, s.7(2)(a)-(c)
Section 7(3) requires the IFR, in exercising its functions, to also have regard (so far as relevant) to: its regulatory principles (section 8); its most recent state of the game report (section 10); the most recent football governance statement published by the Secretary of State (section 11); any guidance it has published (section 12); and any guidance published by the Secretary of State (section 13).
Football Governance Act 2025, s.7(3)(a)-(e)
Section 7(4) imposes a continuing monitoring duty: “The IFR must keep under review the extent to which persons are complying with obligations imposed on them under or by virtue of this Act.” This is the statutory basis for the IFR’s ongoing compliance-monitoring function, distinct from its case-by-case licensing and enforcement powers.
Football Governance Act 2025, s.7(4)
The regulatory principles (Section 8)
Section 8 sets out eight regulatory principles that must inform how the IFR exercises every protective function under the Act. These principles do not create freestanding duties to protect football; rather, they constrain and shape the manner in which the IFR discharges the duties and objectives set out in sections 1, 6 and 7.
| Principle | Statutory text (summarised) |
| s.8(a) Efficiency | The IFR should use its resources in the most efficient, expedient and economic way. |
| s.8(b) Cooperation | The IFR should, so far as reasonably practicable, cooperate and proactively and constructively engage with (i) persons on whom it may impose requirements or restrictions, clubs, owners, senior managers and other officers of clubs, and competition organisers, and (ii) other affected persons, including players and fans. |
| s.8(c) Necessity | Before imposing any requirement or restriction, the IFR should have regard to whether it is necessary and whether a similar outcome could be achieved by less burdensome means. |
| s.8(d) Proportionality | Any requirement or restriction imposed should be proportionate to the benefits expected to result from it. |
| s.8(e) Football-context sensitivity | The IFR should act having regard to the specific context of football and the fact that clubs are already subject to rules, requirements and restrictions imposed by competition organisers. |
| s.8(f) Consistency | The IFR should act consistently, subject to recognising differences between clubs and competitions and the differing circumstances affecting them. |
| s.8(g) Recognition of owner/officer responsibility | The IFR should act in a way that recognises the responsibilities of owners, senior managers and other officers of clubs in relation to requirements placed on clubs under the Act. |
| s.8(h) Transparency | The IFR should act as transparently as reasonably practicable. |
Football Governance Act 2025, s.8(a)-(h)
The licensing regime as the primary protective mechanism
Part 3 of the Act establishes the operating licence as the gateway mechanism through which the IFR’s protective duties are made operationally real. Section 15(1) prohibits a club from operating a relevant team unless it holds a provisional or full operating licence.
Football Governance Act 2025, s.15(1)
The threshold requirements (Schedule 4)
A full operating licence may only be granted where the “full licence test” in section 18(3) is met, which requires (among other things) that the club meets the threshold requirements set out in Schedule 4. Schedule 4, paragraph 1 sets out three threshold requirements: the financial resources threshold requirement (para.2), the non-financial resources threshold requirement (para.3), and the fan engagement threshold requirement (para.4).
Football Governance Act 2025, s.18(3)(a)(ii); Sch.4 para.1(a)-(c)
The fan engagement threshold requirement, in particular, gives statutory force to the protective purpose identified in section 1(3)(a): it is met only where the club has “adequate and effective means by which (a) the club consults its fans about the relevant matters, and (b) the club takes the views of its fans into account in making decisions about the relevant matters”, with “relevant matters” expressly including the club’s strategic direction, business priorities, operational and matchday issues including ticket pricing, the club’s heritage, and plans for additional fan engagement.
Football Governance Act 2025, Sch.4 para.4(1)-(2)
Mandatory and discretionary licence conditions
Section 20 requires the IFR to attach the mandatory licence conditions set out in Schedule 5 to every club’s operating licence. Section 21 additionally permits the IFR to attach discretionary licence conditions, but only where it is satisfied that compliance would ensure or contribute to the club meeting (or continuing to meet) the threshold requirements, or would advance the systemic financial resilience objective (section 21(3)(a)-(c)).
Football Governance Act 2025, ss.20, 21(3)(a)-(c)
Section 22 confines the scope of discretionary financial conditions tightly: a condition relating to the financial resources threshold requirement may only relate to debt management, liquidity requirements, restricting overall expenditure, or restricting funding reasonably suspected to be connected to serious criminal conduct (section 22(1)(a)-(d)). A condition relating to the systemic financial resilience objective may only relate to debt management, liquidity requirements, or restricting overall expenditure (section 22(3)(a)-(c)) — and, in either case, may not target a particular kind of expenditure or a particular transaction (section 22(4)).
Football Governance Act 2025, s.22(1)(a)-(d), (3)(a)-(c), (4)
Revocation as a protective power
Section 19 permits the IFR to revoke a club’s provisional operating licence where the full licence test is not met and the club has persistently and without reasonable excuse failed to take reasonable steps to meet it, with no reasonable prospect of meeting it even with further time. Significantly, section 19(4) protects the football season itself as a unit to be safeguarded: where a revocation notice is given during a football season, the revocation date specified may not fall before the end of that season.
Football Governance Act 2025, s.19(1)-(4)
Owner and officer suitability as a protective duty (Part 4)
Part 4 of the Act imposes a parallel and distinct protective mechanism, directed not at the club’s resources but at the suitability of the individuals who own and run it. Section 27 imposes duties to notify the IFR of a prospective new owner or officer; sections 28 and 29 require the IFR to determine the suitability of new owners and new officers respectively before they take up that role; section 30 addresses the consequences of becoming an owner or officer without such a determination; and sections 33 to 36 impose parallel duties in relation to incumbent owners and officers, including a duty to notify the IFR of a material change in circumstances (section 33).
Football Governance Act 2025, ss.27-36
Section 37 specifies the matters relevant to these suitability determinations. Where an owner or officer is found unsuitable, sections 38 to 44 provide the IFR with a graduated suite of enforcement tools: disqualification orders (s.38), removal directions for owners (s.39) and officers (s.40), directions relating to unsuitable owners and officers generally (s.41), orders effecting alternative officer arrangements (s.42), and, as the most severe sanction, ownership removal orders (s.43), with section 44 governing the procedure, costs and liabilities associated with such orders.
Football Governance Act 2025, ss.37-44
Specific duties on clubs and competition organisers (Part 5)
Part 5 imposes a defined set of specific statutory duties directly on regulated clubs (and, in some cases, on bodies that have been regulated clubs within a defined preceding period), which collectively operationalise the protective objectives identified in sections 1 and 6:
| Provision | Statutory duty |
| s.45 Prohibited competitions | A club must not operate a team in a competition the IFR has specified as “prohibited”, the specification power requires the IFR to have regard to whether the competition is merit-based, operates on fair and open competition, and whether it would jeopardise the sustainability of competitions or clubs, or harm the heritage of English football (s.45(5)(a)(i)-(v)). |
| s.46 Home ground disposal | Duty to notify and obtain IFR approval before disposing of, or using as security, any interest in the home ground (see Section 2.3 above for detail). |
| s.47 Administrator appointment | A body may not have an administrator appointed under Schedule B1 to the Insolvency Act 1986 without prior written IFR approval, which must accompany the relevant insolvency notice filings. |
| s.48 Relocation | Duty to notify and obtain IFR approval before relocating home matches (see Section 2.3 above for detail). |
| s.49 Crest, colours, name | Duty not to make material changes without fan support / FA approval (see Section 2.3 above for detail). |
| s.50 Notification of material change | Duty to notify the IFR of any material change in circumstances relevant to the exercise of the IFR’s functions, save where already notified under another provision. |
| s.51 Insolvency transparency | A regulated club in relevant insolvency proceedings must take reasonable steps to keep its fans informed about the progress of those proceedings. |
| S.52 Personnel statement | A licensed club must prepare and submit for IFR approval a personnel statement identifying its owners, officers, and ultimate owner, and must publish the approved statement online. |
| s.53 Levy | The IFR may require a licensed club to pay a levy, calculated under levy rules that must not allow recovery beyond the IFR’s actual and projected costs of exercising its functions (s.53(3)(a)-(d)). |
Football Governance Act 2025, ss.45-53
The revenue distribution mechanism as systemic protection (Part 6)
Part 6 provides a distinct mechanism through which the IFR protects the systemic financial resilience objective at the level of relations between competition organisers (principally, as a matter of practical application, the Premier League and the English Football League), rather than at the level of an individual club.
Section 56(1) describes the mechanism: a specified competition organiser may apply for a process to be triggered under which organisers are required to enter mediation regarding the distribution of “relevant revenue” (broadcast rights revenue, or other revenue specified by regulations: s.56(2)(a)-(b)), and if mediation fails, the IFR may make a binding distribution order (sections 60 to 64 set out the mediation stage, proposal stage, the distribution order itself, its duration and revocation, and review/costs provisions).
Football Governance Act 2025, s.56(1)-(2); ss.60-64
Section 57 sets out four alternative statutory conditions under which an organiser may apply to trigger this process, broadly: the absence of any agreement or order (Condition 1); a material revenue reduction compared to a prior agreement/order period (Condition 2); a material change in circumstances since the last agreement/order (Condition 3); or an agreement that has been in force for at least five years with no order in effect (Condition 4).
Football Governance Act 2025, s.57(3)-(6)
Section 59(2) imposes a three-part conjunctive test the IFR must satisfy before triggering the process: it must be satisfied that a section 57 condition is met (s.59(2)(a)); it must have reasonable grounds to suspect that its ability to advance at least one of its objectives would be jeopardised if the process were not triggered (s.59(2)(b)), directly tying this mechanism to the protective objectives in section 6; and it must consider that the questions for resolution could not be resolved within a reasonable time by the IFR’s other functions (s.59(2)(c)).
Football Governance Act 2025, s.59(2)(a)-(c)
Information, investigation and enforcement powers (Parts 7-8)
The protective duties and objectives identified above are backed by a substantial suite of investigatory and enforcement powers. Section 65 gives the IFR power to require information; section 66 permits the commissioning of reports on clubs by expert reporters; section 67 defines “relevant infringement”; sections 68 to 71 govern investigations, their outcomes, and commitments accepted in lieu of investigation; section 72 imposes a duty to preserve information; section 73 addresses privileged communications; and section 74 requires the publication of certain notices.
Football Governance Act 2025, ss.65-74
Section 75 provides for sanctions, with sections 76 and 77 governing the procedural safeguards of warning notices and decision notices respectively. Section 78 creates statutory offences, and section 79 gives the IFR power to issue urgent directions, a power of particular relevance to the protective purpose of the Act, allowing the IFR to act swiftly in circumstances of acute risk to a club or to the wider game, rather than being confined to the standard notice-and-representations procedure that applies elsewhere in the Act (for example, under sections 17, 18, 23 and 45, each of which requires a minimum 14-day representation period before action is taken).
Football Governance Act 2025, ss.75-79; cf. ss.17(5), 18(5), 23(4), 45(7)
Reporting duties that operationalise the protective function
The Act imposes three principal reporting duties on the IFR that are directly tied to its protective function:
| State of the game report (s.10) | Must include an overview of the main issues affecting English football, and, critically, “an assessment of whether any feature, or combination of features, of English football jeopardises, or risks jeopardising, the IFR’s ability to advance one or more of its objectives” (s.10(2)(b)). The first report must be published within 18 months of the relevant regulations coming into force (s.10(3)); subsequent reports at least every five years (s.10(4)). |
| Football governance statement (s.11) | A statement the Secretary of State may (not must) prepare, setting out government policy on football governance, but section 11(2) provides that it “may not contain any policies that are inconsistent with the purpose of this Act or with the IFR’s objectives,” preserving the primacy of the IFR’s statutory protective duties over executive policy preference. |
| Annual report (s.14) | The IFR must submit an annual report to the Secretary of State on the exercise of its functions, to be laid before Parliament, providing a recurring accountability mechanism for how the protective duties set out above have actually been discharged. |
Football Governance Act 2025, ss.10(2)(b), (3)-(4); 11(2); 14
Conclusion
The Football Governance Act 2025 constructs the IFR’s protective duty in a deliberately layered fashion.
At the foundation sits a single statutory purpose (section 1(1)) defined by reference only to fan interest and community contribution (section 1(3)). That purpose is operationalised through three named objectives (section 6), club financial soundness, systemic financial resilience, and heritage, each given distinct and separately enforceable statutory content through the licensing regime, the discretionary condition powers, and the specific duties in Part 5. The exercise of every one of these protective powers is itself constrained by the general duties in section 7 and the eight regulatory principles in section 8, which require proportionality, necessity, football-context sensitivity, and transparency. The result is a statute in which the protection of English football is not a general discretion but a structured, textually precise set of obligations, each traceable to specific sections and Schedules, and each subject to procedural safeguards (consultation, representations, notice periods) before the IFR may act.
Article prepared from direct analysis of the Football Governance Act 2025 (c. 21), as enacted. All statutory references are to sections and Schedules of that Act unless otherwise stated.