Football Governance Act & Independent Football Regulator 

A new licensing regime will become a central feature of the regulatory framework, requiring clubs within scope to satisfy the IFR that appropriate systems, governance and financial controls are in place.

We advise on:

• IFR licence applications
• Governance readiness assessments
• Ongoing licence compliance
• Financial and operational governance
• Regulatory reporting requirements
• Compliance reviews and audits
• Policies, procedures and governance frameworks.

Our aim is to help clubs establish governance structures capable of meeting both current and future regulatory expectations.
 

The Football Governance Act introduces increased scrutiny of club ownership and control arrangements. The suitability of owners, directors and officers is expected to become a key area of regulatory focus.

We advise:

• Prospective club owners and investors
• Existing shareholders
• Directors and officers
• Lenders and financiers
• Private equity investors and consortiums.

We support clients with:

• Ownership and suitability assessments
• Acquisitions and disposals of football clubs
• Change of control transactions
•  Governance reviews
• Regulatory approvals
• Due diligence and risk assessments.

Strong governance sits at the heart of the new regulatory regime. Clubs will be expected to demonstrate effective decision-making, accountability and risk management practices.

Our governance support includes: 

• Board governance reviews
• Director duties advice
• Governance framework design
• Accountability frameworks
• Regulatory policies and procedures
• Board training and workshops
• Governance audits.

We help clubs establish governance structures that support both compliance and long-term success.

Financial resilience is one of the primary objectives of the new regulatory framework. Clubs will increasingly be expected to demonstrate sustainable financial management and appropriate risk controls.

We advise on:

• Financial governance frameworks
• Risk management processes
• Internal controls
• Regulatory reporting 
• Insolvency and restructuring risks
• Investment structures
• Funding arrangements.

Drawing on expertise across our banking, finance, restructuring and corporate teams, we provide integrated support on complex financial matters.
 

The Football Governance Act places greater emphasis on supporter engagement and the protection of key aspects of club heritage. Clubs will be expected to engage with supporters on certain significant decisions and to consider heritage-related protections.

We advise on:

• Fan engagement frameworks
• Consultation processes
• Governance arrangements
• Heritage protection requirements
• Policy development
• Regulatory compliance obligations.
   

The IFR will have investigatory and enforcement powers where concerns arise regarding compliance with regulatory requirements.

We advise clubs, directors and investors on:

• Regulatory investigations
• Information requests
• Enforcement proceedings
• Governance failings
• Licence compliance issues
• Remediation programmes
• Regulatory appeals and challenges.

Our regulatory and public law expertise enables us to support clients through both contentious and non-contentious regulatory matters.

The Football Governance Act introduces a new statutory framework for the regulation of English football and establishes the Independent Football Regulator to oversee clubs operating within the scope of the regime.

The Football Governance Act establishes the Independent Football Regulator as the new statutory regulator for English football. 

The regulator's objectives include: 

1. Promoting financial sustainability
2. Protecting club heritage
3. Improving governance standards across the game.

The IFR will have significant powers in relation to:

• Club licensing
• Ownership and control
• Corporate governance
• Financial sustainability
• Fan engagement
• Regulatory compliance
• Investigations and enforcement.

We help clubs and stakeholders understand how these requirements apply to their organisation and prepare for future regulatory obligations.

The regime is expected to apply to clubs within the top five tiers of the men's football pyramid in England. 

For clarity, it refers to 116 teams playing in the:

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

Yes, clubs playing in the top five leagues will need to obtain and maintain a licence issued by the IFR.

Clubs should review their governance structures, ownership arrangements, financial controls, compliance frameworks and fan engagement processes now to identify gaps and prepare for implementation of the new regime.

Our Football Governance Act solicitors are here to assist you with your preparation.