It is not just Christmas lights that have been switched on in December 2025.
Readers will be aware that the Football Governance Act 2025, which received Royal Assent in July, marks a significant shift in the regulation of English football. At its core, the Act establishes the Independent Football Regulator (IFR), a new statutory body tasked with promoting the financial sustainability of clubs, safeguarding the heritage of the game, and ensuring good governance across the sport. The IFR’s remit covers the top five tiers of men’s football in England, including the Premier League and the National League.
What has happened?
On 12 December 2025, a second wave of the Act’s provisions came into force under the Commencement No. 2 Regulations. These newly active sections focus on four key areas:
- Suitability of club owners and officers;
- Investigatory powers;
- Enforcement mechanisms; and
- Review and appeal procedures.
While the licensing regime and financial levy provisions remain pending, this latest commencement marks a major step in operationalising the IFR’s oversight powers.
The suitability provisions now in force will allow the IFR to assess whether incumbent owners and senior officers meet the required standards of honesty, integrity, financial soundness, and – where applicable – managerial competence. The IFR can issue disqualification orders or removal directions where individuals are found unsuitable. Clubs will be required to notify the IFR of any changes in ownership or executive leadership.
The IFR’s investigatory powers have also been activated. These include the ability to issue formal information notices, appoint expert auditors, and require clubs to preserve relevant documents. Importantly, while legal privilege is protected, there are no exemptions for commercially sensitive information. Clubs must be prepared to respond to information requests promptly and transparently.
Enforcement provisions will give the IFR the authority to impose sanctions for non-compliance. These range from public censures to financial penalties, which can reach up to 10% of a club’s global revenue or an individual’s remuneration. In serious cases, the IFR may suspend a club’s licence or seek injunctive relief. The regulator also has powers to act urgently where immediate intervention is necessary.
To ensure accountability, the Act introduces a structured review and appeal process. Affected parties can request an internal review of IFR decisions, and if dissatisfied, escalate the matter to the Competition Appeal Tribunal (the CAT). The CAT can assess decisions on their merits or, in some cases, apply judicial review standards. This layered approach provides a degree of legal oversight and recourse for clubs and individuals.
Consultations
In parallel with these developments, the IFR has launched three consultations to shape its regulatory approach. The first outlines the proposed Owners, Directors and Senior Executives (ODSE) regime, detailing how the IFR will assess the suitability of individuals in key roles. The second consultation addresses the IFR’s information-gathering and enforcement procedures, emphasising a cooperative rather than punitive approach. The third focuses on the sanctions framework, proposing a stepped methodology for determining penalties based on the severity of breaches and mitigating factors.
These consultations, which closed in October, are expected to inform the IFR’s final guidance and operational policies. Clubs should anticipate definitive guidance from the IFR in 2026, particularly as the licensing regime and levy provisions are brought into force.
Clubs- going forwards
“It’s Christmastime, there’s no need to be afraid”
This sentiment sounds familiar at this time of year and the Band Aid opening lines are useful watch words for clubs considering what these regulatory changes mean for them. The IFR has stated it will look to collaborate with clubs, and all stakeholders, to achieve transparent and proportionate governance. Sounds good to us.
The era of self-regulation is ending, and a new compliance culture is emerging. This represents an opportunity for clubs. Whilst the development of the regulatory framework plainly creates some additional risk, the switching on of certain powers represents an opportunity to re-appraise governance structures, financial practices, and leadership appointments, to ensure they will ultimately align with the IFR’s standards. Proactive engagement with the regulator, internal compliance reviews, and legal preparedness will be important to navigating this evolving landscape.
As the IFR continues to roll out its full suite of powers, stakeholders across the football industry should remain alert to further regulatory developments. The Football Governance Act 2025 represents a re-calibration when it comes to governance in English football, one that places sustainability, transparency, and accountability at the heart of the game’s future. Our work with clubs throughout the pyramid has taught us that clubs are resilient and able to adapt to a developing regulatory framework. This resilience will be needed in the months and years ahead, but the evolution of the framework here represents an opportunity for clubs, rather than a reason to necessarily be afraid.
For a complimentary initial consultation to discuss this matter, or any additional regulatory concerns at your club, please contact Tim Williamson, Partner in Clarke Willmott LLP’s specialist Sports Regulatory team, based across England and Wales.
Co-written by Matthew Burgess, paralegal in our Commercial and Private Client Litigation team.
