Key takeaways
Football Governance Act 2025 established a new Independent Football Regulator
Designed to safeguard financial stability, strengthen club governance, and enhance supporter involvement.
The IFR has been granted wide regulatory authority
Responsible for club licensing, ownership scrutiny, financial oversight, and guiding the transition to the new Squad Cost Ratio system.
Regulator’s work is expected to generate new legal touchpoints
Spanning competition‑law implications, ownership‑related disputes, and compliance with evolving financial, operational, and data‑governance obligations.
The introduction of the Independent Football Regulator (IFR) potentially marks one of the most significant structural changes to English football in a generation. Established under the Football Governance Act 2025, the IFR represents the UK Government’s first major statutory intervention in domestic football governance. Its creation reflects rising concerns around club finances, ownership transparency, supporter engagement, and the limitations of a self‑regulatory model for the modern game.
Why introduce the IFR?
The IFR stems from the recommendations of the 2021 Fan‑Led Review of Football Governance, which identified persistent vulnerabilities across the professional football pyramid. By 2025, Government concluded that voluntary reforms had been insufficient. A combination of club failures, governance lapses, and inconsistent financial controls provided the impetus for moving towards a statutory regulator. Long‑standing issues relating to ownership suitability, safeguarding shortcomings, and governance fragmentation reinforced the case for intervention.
The establishment of the IFR marks a shift from a hands‑off approach to a more involved form of government oversight, creating a closer and more interventionist dynamic between Government and the sport’s traditional regulators.
The IFR’s powers
The Act grants the IFR extensive regulatory competence covering the 116 clubs across the top five tiers of English football. Its functions include:
club licensing, requiring evidence of sound financial management and operational resilience;
oversight of club ownership and director suitability, reflecting concerns around transparency and integrity;
mandating supporter engagement, embedding structured fan‑consultation requirements; and
financial regulation, including responsibility for guiding clubs through the move away from the Premier League’s backward-looking Profit & Sustainability Rules (the long standing financial fair play model in respect of which legacy cases are still being concluded) to the new (forward-looking) Squad Cost Ratio (SCR) model.
Timescales
With the Act now operative, the IFR is beginning to assume its regulatory functions. Regulatory frameworks and licensing requirements are being phased in to allow clubs to adjust. This transitional period also coincides with the industry’s full adoption of the SCR system. From the 2027-28 season, all clubs will be required to hold a licence.
What has the Regulator done so far?
The IFR’s first months have centred on building regulatory infrastructure. Early work has focused on developing licensing criteria and consultation processes; engaging with Premier League financial‑reform implementation; and reviewing ownership and governance risks.
What it is hoped the Regulator will achieve
The IFR is intended to strengthen the structural health of English football by:
improving financial resilience;
ensuring greater transparency in ownership;
enhancing competitive integrity; and
supporting meaningful fan participation.
What legal issues might arise?
The change may open the door to:
jurisdictional disputes involving the FA, Premier League, and UEFA;
competition‑law challenges (particularly following the decision of the CJEU regarding the break away European Super League);
financial‑compliance disputes under the SCR regime;
challenges to ownership and takeover decisions; and
data‑governance and privacy issues.
What now?
Clubs and advisors should:
strengthen governance, risk, and compliance frameworks;
stress‑test financial models for SCR compliance;
review ownership and corporate structures;
prepare for more robust disclosure obligations; and
monitor developing IFR guidance and consultations.
Hill Dickinson provides tailored sector-focused support to help clubs and advisors navigate compliance requirements, disputes, corporate, finance, governance, and risk matters. Get in touch, we are happy to help you.
