English football generated more than £9 billion in revenue in the IFR’s 2025/26 dataset. Yet 94% of clubs across the top five divisions were loss-making before tax, and two-thirds of clubs responding to its funding exercise said they could not survive beyond 90 days without new owner funding. The report explains how those conditions developed. For owners, boards, CEOs and CFOs, it also sets out the work required to build a club that can withstand a financial shock.

On 2 November, the Independent Football Regulator opens the application window that will decide whether every club in England's top five divisions can keep playing professional football beyond the summer of 2027. For the majority of clubs below the Premier League, many without a dedicated compliance function, the deadline that actually matters is not 26 February. It is today.

The Premier League's published commission decision, finding against Manchester City on all but one of the charges referred to it, has prompted a blunt question: could the Independent Football Regulator now intervene? It could, but each power has its own test. The IFR can ask for evidence about the club's finances and controls. Assessing an owner under section 34, refusing a licence or forcing a sale would require further steps. Here is what the Act allows today, and what City's first licence application may have to address.

Everything written about IFR enforcement before this summer was, necessarily, theoretical -- careful analysis of what the Act permits, illustrated with hypothetical scenarios. That changed in 2026. The IFR's actual first enforcement case, against Morecambe FC and its two directors, is now a matter of public record, documented in the regulator's own published notices from start to finish. It is a far better teacher than any hypothetical, precisely because nothing about it had to be imagined. This is what genuinely happened, in the order it happened, and what it actually tells clubs about how this regulator behaves in practice.

A football club can survive a poor season. It can survive relegation, a difficult transfer window, even a genuinely bad manager appointment. What no club has ever survived, or ever will, is losing its supporters' consent to exist as the club they believe it to be. The Football Governance Act 2025 has now written that truth into statute, making fan consultation a mandatory condition of every operating licence. But the regulation did not create the underlying reality. It simply caught up to something English football learned, in the space of about forty-eight hours in April 2021, in the most dramatic way the modern game has ever demonstrated it.

Neither the Football Governance Act 2025 nor the IFR’s final licensing framework requires every football club board to review a prescribed pack each month. The framework does, however, require recurring regulatory reports, board-approved submissions and prompt updates when specified changes occur. The Football Club Corporate Governance Code also expects boards to receive timely, accurate information, oversee material risks and monitor plans, budgets and actions. This article therefore presents a monthly pack as Lagom’s recommended governance practice—not an IFR rule—and explains how each section can support the club’s actual obligations.

A single transfer can involve a buying club, a selling club, a player, one or more agents, an owner or funder, and other payment or holding vehicles. The EU Anti-Money Laundering Regulation (AMLR) does not supply one universal customer for the whole deal -- but it does not make every participant a customer automatically either. From 10 July 2029, an in-scope football agent is an obliged entity, while an in-scope EU professional football club is an obliged entity only for the transactions listed in Article 3(3)(o), including player transfers; some low-risk clubs may be exempted by their Member State. Each obliged entity must map the actual relationship, payment flow and Article 19 trigger before deciding who is its customer and which checks apply.

An IFR investigation can trigger immediate legal obligations, but the Football Governance Act 2025 does not create a general 14-day deadline running from the day an investigation opens. The IFR must normally give the suspected person an investigation notice as soon as reasonably practicable, although it may delay that notice if giving it would prejudice the investigation. The separate statutory minimum of 14 days begins only if the IFR later gives a warning notice because it is minded to take enforcement action. This guide therefore uses the first fortnight as a practical mobilisation period, while distinguishing what the law requires from what good response practice recommends.

A smaller club’s Chair also runs finance. A Chief Executive goes on sudden medical leave before a transfer deadline. A General Counsel delegates routine contract review. These familiar situations raise related but distinct questions under the IFR’s ODSE regime: can one individual hold more than one Senior Management Function (SMF); when may someone cover an absent SMF holder; can responsibility be shared; and what does delegation change? The final rules now answer some of those questions expressly, while others depend on the wording of the particular SMF and the club’s actual governance arrangements.

Suspension or revocation of an operating licence is the IFR's most serious club sanction. The IFR's final guidance describes it as a very last resort, but the Football Governance Act 2025 does not create one mandatory ladder that every case must climb. Schedule 9 permits suspension or revocation after a relevant infringement when one of three additional conditions is met; one of those conditions does not require a history of persistent breaches. A separate section 19 route can revoke a provisional licence where the club persistently fails to take reasonable steps to meet the full licence test and there is no reasonable prospect of doing so in time. The Act's sanctions do not include points deductions or transfer bans. This article explains the routes and their safeguards.

Under the FCA's Senior Managers and Certification Regime, the Duty of Responsibility contains an express reasonable-steps element and the regulator carries the burden of establishing it. The Football Governance Act 2025 uses a different structure. Schedule 7 connects a club's relevant infringement to the senior management function carried out by an individual, while sections 69 and 75 require the IFR to address whether the club and the senior manager had a reasonable excuse. The answer is therefore nuanced: the Act does not reproduce the FCA's three-part reasonable-steps test, but neither does it impose unqualified or automatic liability on an IFR senior manager. This article compares the current statutory and regulatory materials as at 20 August 2026. It is regulatory commentary, not legal advice, and anyone facing an actual investigation should obtain advice on their own circumstances.

Five of the IFR's six Senior Management Functions map relatively neatly onto recognised roles: Chair, Chief Executive, Chief Finance, Chief Operations and Director. The sixth does not. SMF6 -- Other Key Decision Maker -- is a catch-all for people outside SMF1 to SMF5 who exercise sustained, high-level authority or influence over a club's regulated activities. The IFR's final May 2026 ODSE Guidance now gives clubs a non-exhaustive set of in-scope and out-of-scope examples. This article uses that final guidance to examine sporting directors, technical directors, recruitment personnel, legal counsel, medical staff and other borderline roles.

An information notice under the Football Governance Act 2025 can be much broader than a request for a few existing documents. Section 65 allows the IFR to require specified information from any person where it considers the information necessary for one of its functions. A notice may describe categories of information, cover drafts and information in any other form, and require information to be obtained, generated, collected or retained. But the power is not unlimited: the material must be responsive to what the notice specifies or describes, the IFR must consider it necessary for a statutory function, and privileged communications remain protected. This article explains how those rules may apply to emails, board papers, models and information held by advisers.

Most commentary on the ODSE regime focuses on getting through it: the fitness test, the source of wealth check, the application itself. Almost none of it spells out, in plain terms, what can happen to an individual owner, director or senior executive if the IFR decides they are no longer suitable. This article does exactly that -- the financial-penalty rules where a separate enforcement trigger exists, the removal mechanisms and the disqualification power. The central point is that the Act provides a toolkit rather than a single escalation ladder, and disqualification concerns owner or officer roles at regulated clubs rather than involvement in English football altogether.

PEP screening -- checking whether a counterparty holds or has held a position of significant public power -- is one of the oldest and most familiar disciplines in anti-money laundering compliance, and one of the least well understood outside financial services. AMLR brings it directly into football's obligations for the first time. Understood properly, it is not a background check performed once and filed away. It is a structured, ongoing regime with specific legal categories, specific required measures, and a specific logic for why public power creates exactly the kind of financial crime risk this framework exists to manage.

Discussion of AMLR and football tends to focus on the sophisticated end of the sport -- transfer fees, sponsorship deals, fund-structured ownership. AMLR's new EU-wide cash payment limit hits a different, less-discussed part of the game entirely. Football has more genuinely cash-adjacent activity than most compliance commentary assumes, and understanding precisely where a hard payment ceiling actually applies -- and where it does not -- matters for parts of the sport that rarely feature in AML discussion at all.

Here is the fact that reframes this entire comparison before it even begins: an English football club and an EU football club are not, right now, subject to remotely comparable AML obligations. From 10 July 2029, an EU club and its agents become fully fledged obliged entities under AMLR. An English club, as things currently stand, is not a designated AML sector under UK law at all. That gap, not a list of granular rule differences, is the real story for any club or agent operating across both markets.

Buried inside a Regulation that most football clubs still assume applies uniformly to the whole sport sits a single provision that could change that entirely -- for some clubs, in some countries, in some circumstances. Article 5 of AMLR is titled, plainly enough, "Exemptions for certain professional football clubs." What it actually does, once you read it properly rather than skim its headline, is considerably more conditional, more variable, and more dependent on a specific national decision than the word "exemption" tends to suggest. This article explains exactly how it works, where it may genuinely apply, and why treating it as a safe assumption rather than a question to actually put to an adviser is the single most avoidable mistake a club can make about it.