Insights, analysis and events

from Lagom Sports Compliance

Tracking the practical implications of EU 2024/1624, football governance developments, enforcement trends and the compliance issues that matter to clubs, agents and their counterparties.

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IFR Licensing, Football Governance Jonathan Greenstein IFR Licensing, Football Governance Jonathan Greenstein

What happens when an IFR licence application is rejected or appealed? A practical guide to the decision-making process

Most of the published guidance on the Independent Football Regulator's licensing regime, including Lagom Sports Compliance’s own, explains how to apply, what the Threshold Requirements ask for, and what a club's evidence pack needs to contain. Almost none of it explains what actually happens if the application does not succeed. Given that the consequence of an unresolved refusal is a club being unable to operate a team in a specified competition, that is a significant gap. This article closes it.

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IFR Licensing Jonathan Greenstein IFR Licensing Jonathan Greenstein

What IFR licensing means for institutional investors and private equity holding English football clubs

English football has acquired something institutional capital has not previously had to underwrite: a statutory financial regulator with the power to approve or refuse who owns a club, and the power to license or delicense the asset itself. For funds already holding English club stakes, and for those evaluating the sector for the first time, the Independent Football Regulator is not a compliance footnote. It is a new, permanent variable in deal timelines, ownership structuring, financing terms and portfolio-level regulatory risk and it is here to stay.

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Regulatory Update Jonathan Greenstein Regulatory Update Jonathan Greenstein

CJEU rules on agent regulations: the key findings in Case C-209/23 and what they mean for AML

On 16 July 2026 the Court of Justice of the European Union handed down its judgment in Case C-209/23 (RRC Sports). The headline is narrower than the immediate commentary suggests. The Court left the referring court to apply its guidance to most of the contested rules. Two points were expressed more strongly than the rest: the approach rule appears, in any event, to be incompatible with the prohibition on cartels, while the GDPR conclusion on disclosure and publication is unqualified. The latter may have consequences for how agents are diligenced under EU Regulation 2024/1624 from 10 July 2029.

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IFR Licensing, IFR Enforcement, ODSE, go Jonathan Greenstein IFR Licensing, IFR Enforcement, ODSE, go Jonathan Greenstein

What section 34 means for football club owners

Almost everything written about the IFR's owner suitability regime concerns getting through it: the fitness criteria, the source of wealth test, the application process, the timeline. Almost nothing addresses what happens once an owner has cleared that hurdle. The answer, under section 34 of the Football Governance Act 2025, is that an affirmative determination is not a certificate that sits in a drawer. It is a live status the IFR can revisit at any time and every existing club owner, whether newly approved or in position for decades, needs to understand exactly how.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

Setting impact tolerances: how long can a football club survive disruption before real harm occurs?

Ask a club how quickly it would recover from a serious system failure and the honest answer is usually "as fast as possible." That is not an impact tolerance. It is a hope. The discipline that financial services firms were forced to adopt under the FCA's operational resilience framework requires something much harder: a specific, defensible, board-approved limit for how much disruption each critical service can absorb before the harm becomes unacceptable. This article explains how a football club sets one properly, using the club's own most time-critical services as the test case.

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The IFR's expert reporter power explained: what section 66 means for football clubs

Section 66 of the Football Governance Act 2025 gives the Independent Football Regulator a power that has attracted almost no dedicated commentary: the ability to appoint an independent expert reporter to prepare a report on a specific matter at a regulated club, with the possibility that costs or expenses may be made payable by the club under IFR rules. It is frequently confused with the IFR's separate power to appoint a skilled person. The two are not the same tool, they are not triggered at the same point, and understanding the difference matters to any club that wants to know what a genuine IFR enquiry actually looks like.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

What are a football club's "important business services"? Identifying the operations that cannot be allowed to fail

Ask a club's leadership team what the business actually does and the answer, understandably, will be some version of football. Ask which specific services genuinely cannot be allowed to fail, and most boards have never been asked to answer with any precision. The exercise is narrower and more revealing than it first appears, and doing it properly is the essential first step of any genuine operational resilience programme.

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Operational Resilience, Football Governance Jonathan Greenstein Operational Resilience, Football Governance Jonathan Greenstein

Beyond the business continuity plan: what operational resilience really means for a football club

Most football clubs have a business continuity plan. Very few have thought about operational resilience, and the distinction is not semantic. A continuity plan tells you what to do after something breaks. Operational resilience asks a harder question: can the club keep delivering the services that matter, throughout the disruption, not just after it. Financial services firms were forced to make this shift five years ago. Football clubs are about to discover why it matters to them too.

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Regulatory Update Jonathan Greenstein Regulatory Update Jonathan Greenstein

CJEU ROGON judgment: why football agent regulation is moving in one direction

The Court of Justice of the European Union has handed down a judgment that matters well beyond German football.

In Case C-428/23, ROGON and Others, the Court considered whether the German Football Association’s rules on player agents may fall within an exception to the EU prohibition on cartels. The press release headline is deliberately careful. The DFB rules may fall within the exception. The Court has not finally decided that the rules are lawful. That question now goes back to the German Federal Court of Justice.

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English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

The Football Club Corporate Governance Code: what regulated clubs must now apply, explain and evidence

The Football Club Corporate Governance Code is not a generic governance handbook. It is the framework regulated clubs must apply and explain through their corporate governance statement. Boards now need to evidence purpose, strategy, risk oversight, board accountability, EDI and stakeholder engagement in a way that is proportionate and credible.

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English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR Licensing Rules: the procedural obligations behind the operating licence regime

The IFR Licensing Rules are short, but clubs should not underestimate them. They turn guidance, templates, approvals and submission windows into binding procedural requirements. Failure to comply may constitute a relevant infringement and lead to investigation or enforcement action.

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English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR Licensing Guidance: what ongoing licence compliance now means for regulated clubs

The IFR Licensing Guidance is the document that turns a provisional licence into an ongoing compliance relationship. Clubs must submit financial plans, governance statements, fan consultation reports and annual declarations, then keep those submissions accurate as their circumstances change.

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English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein English Football, Regulation & Compliance, IFR Licensing Jonathan Greenstein

IFR provisional licence application guidance: what regulated clubs must submit before the 2027/28 season

Every club in the top five divisions needs an IFR provisional licence to compete from the 2027/28 season. The application is not a formality. It requires a strategic business plan, financial forecasts, a personnel statement and an authorised declaration, signed by a club director or individual with appropriate authority, confirming that the information is accurate and complete.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

Agent fees, amortisation and the 70% trap: how transfer window decisions drive UEFA financial sustainability risk

Clubs spent a record USD 1.37 billion on agent fees in 2025. Every pound of that sum sits in the numerator of UEFA's Squad Cost Rule. Combined with wages and transfer amortisation -- the other two numerator components -- agent fees mean that a single active summer transfer window can move a club's squad cost ratio by several percentage points in the space of six weeks. This article explains precisely how that happens, why it matters, and what a compliance-aware transfer window strategy looks like.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

UEFA's escalating consequence model in practice: examining the Aston Villa June 2026 decision

Aston Villa's outcome from the UEFA CFCB monitoring cycle of 30 June 2026 is the most instructive single data point in European football's regulatory landscape this summer. It is the only English club to receive a significant breach finding under the Squad Cost Rule, the only English club to face a List A registration restriction for a UEFA competition, and -- at €22.5 million -- the largest conditional fine imposed on any English club in the current enforcement cycle. Used correctly, the Villa decision is a precise illustration of how UEFA's escalating consequence model actually functions. This article explains it.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

How UEFA financial sustainability rules interact with the IFR licensing regime: what English clubs in both frameworks need to know

English football clubs are the only clubs in the world simultaneously subject to UEFA's Club Financial Control Body monitoring and the Independent Football Regulator's operating licence regime. Two regulators, two financial sustainability frameworks, two sets of information requirements, two sets of deadlines -- with some objectives that reinforce each other and others that pull in different directions. This article maps the intersections, the tensions and the compliance implications of operating in both simultaneously.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA CFCB settlement agreement: what it is, what it commits you to and why it is not a get-out

When Newcastle United and Juventus entered settlement agreements with UEFA's Club Financial Control Body in June 2026, some coverage framed the outcome as a deal struck, a fine agreed and a matter resolved. That framing misunderstands what a settlement agreement is. It is not a resolved matter. It is the beginning of a three-year compliance programme, with annual targets, public reporting obligations and escalating consequences, up to and including exclusion from UEFA competition, if those targets are not met.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA Football Earnings Rule: what replaced FFP, how the three-year test works and why Newcastle fell foul of it

UEFA's Financial Fair Play rules are gone. In their place sits a more sophisticated, more demanding framework: the Football Earnings Rule, which assesses a club's financial sustainability across a rolling three-year period and permits aggregate losses of up to €60 million before triggering a significant breach. Newcastle United became the first English club to be sanctioned under the FER in the June 2026 enforcement cycle. This article explains what the rule requires, how it differs from FFP, and what clubs need to understand about managing their position across a three-year horizon.

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UEFA Club Licensing 2025 Jonathan Greenstein UEFA Club Licensing 2025 Jonathan Greenstein

The UEFA Squad Cost Rule explained: what the 70% cap means, how it is calculated and why clubs breach it

Four Premier League clubs breached the UEFA Squad Cost Rule in the 2025 calendar year. The rule itself, a 70% cap on aggregate squad costs relative to relevant revenues, is deceptively simple in concept and genuinely complex in application. This guide explains precisely what it requires, how the ratio is calculated, what counts in the numerator and what does not, and what the consequences of a breach look like in practice.

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