Why football regulation is changing the governance agenda
The Independent Football Regulator represents a major change in how football clubs will be expected to evidence good governance, financial sustainability and accountability. Under the Football Governance Act 2025, clubs in scope will need to operate within a licensing regime, demonstrate financial soundness and show that owners, directors and senior executives meet suitability requirements. For clubs, boards and investors, the challenge is no longer simply to meet regulatory tests but to build governance and control environments that are transparent, resilient and defensible.
What is the Independent Football Regulator?
The Independent Football Regulator (IFR) has been established to help protect the long-term sustainability of English football. Its objectives include protecting and promoting the financial soundness of regulated clubs, strengthening the financial resilience of the game and safeguarding football heritage. In practice, this means greater scrutiny of how clubs are governed, funded, controlled and led. The regime is built around licensing. Clubs in scope will need an operating licence, and the IFR can attach mandatory and discretionary conditions. Governance is becoming more than a matter of good practice. It is becoming part of the regulated framework through which financial soundness, resilience and accountability will be assessed.
How does the IFR affect football club governance?
The corporate governance implications are significant. Clubs will be expected to report on their governance arrangements against a football club corporate governance code developed by the IFR with stakeholders. They will also need to publish information on equality, diversity and inclusion and explain their contribution to the economic and social well-being of their local community.
That moves governance from an internal board matter into a more visible, reportable and reputationally sensitive requirement. Clubs will need to be able to evidence how decisions are made, who has authority, how risks are overseen and how board information supports effective challenge:
- clear governance structures and delegated authorities
- properly documented board and committee responsibilities
- robust reporting to support oversight and challenge
- effective risk management and internal control frameworks
- evidence that major decisions are properly assessed, approved and recorded.
What does the ODSE regime mean for owners and senior leaders?
The Owners, Directors and Senior Executives (ODSE) regime formalises scrutiny of those who own, direct or exercise significant influence over a regulated club. The IFR will assess prospective owners and senior managers before they take up their roles and may assess incumbents where there are grounds for concern.
The scope goes beyond formal job titles. Senior Management Functions include roles such as Chair, Chief Executive, Chief Finance, Chief Operations, Director and other key decision-makers. However, the guidance also focuses on substance over form: an individual may be in scope if they exercise the responsibilities of a role, even if their title is different.
For clubs, this creates a need to identify who really exercises control or influence. Shadow directors, highly influential individuals and beneficial owners may all attract scrutiny. Clubs will also need processes to notify the IFR when there is a reasonable prospect of someone becoming an owner or senior manager, and to disclose material changes that may affect ongoing suitability.
Why financial sustainability is now a board-level issue
Financial sustainability sits at the centre of the new framework. Clubs will need to demonstrate sound financial practices, credible funding and resilience to financial shocks. Prospective owners will need to evidence how the club will be operated, how costs will be funded and whether they have sufficient financial resources to support the club’s strategy and commitments.
The source of wealth is also a regulatory issue. Applicants must explain and evidence where funds come from, and clubs are expected to undertake their own due diligence before applications are submitted. Financial distress in connected entities, failures to meet liabilities or weak financial planning may create regulatory concern.
Core assets are part of the sustainability picture too. Home grounds, stadium sales, relocation and other major decisions may carry financial, governance and heritage implications. This means long-term financial stewardship should be considered alongside risk appetite, asset protection and stakeholder confidence.
What should clubs and boards do now?
The clubs likely to be best placed will be those that can show their governance, risk and control arrangements are clear, current and operating effectively. This is not only about preparing for regulation; it is about building a stronger management framework for decisions that affect the future of the club.
Practical steps include:
- mapping governance structures, delegated authorities and decision rights
- identifying owners, senior managers and other influential decision-makers
- reviewing appointment, notification and suitability processes
- testing financial plans against funding, cashflow and downside scenarios
- strengthening due diligence over ownership, source of wealth and connected parties
- reviewing controls over major commitments, assets and strategic decisions
- assessing whether risk management, internal audit and assurance arrangements are proportionate.
Preparing for a more scrutinised environment
The IFR regime signals a broader expectation that football clubs will operate with disciplined governance, stronger financial planning and clearer accountability. For boards, owners and senior leaders, the priority should be to understand where existing arrangements are robust, where evidence is incomplete and where controls need to be strengthened.
How Crowe can help
Crowe supports sporting organisations with governance, risk and resilience services that help leadership teams turn regulatory expectations into practical, workable frameworks. Our work with Andretti Formula E demonstrates the value of strengthening governance and control environments in a highly regulated sporting context, including support across risk and assurance, accounting, corporation tax and VAT.
Our specialist Risk and Assurance team can support clubs, teams, governing bodies and sports-related organisations with internal audit, risk management framework development, governance and board effectiveness reviews, technology and cyber risk assurance, third-party risk, resilience reviews, data governance and project assurance.
If you would like to discuss how Crowe can support your organisation with football club governance, financial sustainability, risk management or Independent Football Regulator readiness, please get in touch with our team.
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