Licensing, oversight, and fan power: inside the Football Governance Act
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The Football Governance Act 2025 has now received Royal Assent, introducing the UK’s first Independent Football Regulator (the "IFR") and marking a fundamental shift in how English football is governed.
For clubs, investors and stakeholders, this represents a new compliance landscape – particularly for those operating in or entering the top five tiers of the "beautiful game".
Key takeaways
1. A new licensing regime
All clubs in the top five tiers will require a licence to operate. The IFR will assess clubs against financial sustainability, governance, and fan engagement standards. Clubs must first apply for a provisional operating licence, which can be valid for up to three years. During this period, clubs are expected to transition to a full operating licence by meeting all the IFR’s financial, governance and fan engagement standards. Clubs must therefore prepare to submit business plans, funding disclosures and evidence of robust internal controls.
2. Enhanced scrutiny of ownership
The Act introduces a strengthened "Owners’ and Directors’ Test". The IFR will have powers to disqualify unsuitable owners – or determine the suitability of prospective ones – and, in extreme cases, compel the sale of a club. Investors should expect more rigorous due diligence and transparency requirements.
3. Fan engagement and heritage protections
Clubs will be required to periodically consult fans on key decisions, including changes to names, badges, and stadiums. In consulting with the fans, clubs may, for example, may need to create a consultation group comprised of representatives, based on the size and composition of the club’s fanbase, and the club’s financial and non-financial resources. This formalises the role of supporters in governance and may impact commercial flexibility.
4. Restrictions on breakaway leagues
Participation in closed-shop competitions like the European Super League is now subject to IFR approval. This provides regulatory certainty but may limit strategic options for clubs seeking international expansion.
5. Tailored regulation and transitional period
The IFR will adopt a proportionate, risk-based approach. Clubs will first apply for a provisional licence, with full compliance expected within three years. This phased implementation offers time to adapt but requires early engagement.
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Subscribe nowStrategic considerations
The Act introduces new compliance obligations and offers a more stable and transparent framework for investment and growth. The IFR is expected to work collaboratively with clubs, tailoring conditions to financial risk and operational scale. This presents an opportunity for clubs to professionalise governance and build resilience.
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Investors |
Clubs |
Commercial partners |
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The Act introduces a predictable but regulated environment. While it may deter speculative ownership, it enhances long-term value for responsible investors. |
Early preparation is key. Governance structures, financial reporting, and fan engagement mechanisms should be reviewed now to avoid future disruption. |
The Act may influence brand strategy, particularly where heritage elements are involved. Stakeholder alignment will be increasingly important |
The IFR created by the Act will begin operations later this year, following a consultation period with clubs, leagues, and fan groups. This means that while the legal framework is now in place, the licensing regime and regulatory enforcement will be phased in.
No fixed deadline has been publicly announced yet for when all clubs must hold a full licence. The IFR is expected to begin operations in late 2025, and licensing will roll out shortly thereafter. We are advising clients across the football ecosystem on how best to prepare for the new regime. If you would like to discuss the implications for your organisation, please get in touch.
