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.

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.

I write and talk to club C-suite about the Independent Football Regulator for a living. Lagom Sports Compliance advises clubs on it, we draft the guidance and sit across the table from boards trying to work out what a mandatory condition actually requires of them in practice. But every so often it is worth stepping back from the advisory language and asking a more honest question: if I actually sat in the chief executive's chair at a regulated club right now, what would genuinely keep me up at night? Not the version of the IFR that reads cleanly in a briefing note. The version that lands on my desk, my inbox, my own personal record with the Regulator, and the people I am responsible for.

Schedule 9 of the Football Governance Act 2025 gives the Independent Football Regulator the power to require a club to appoint a specialist, nominated by the IFR itself, to help bring an unresolved compliance failure to an end. It is easy to mistake this for a version of the advisory support clubs already engage voluntarily. It is not. The distinction between choosing your own adviser and having one nominated for you by your regulator is the entire point of this article and the most useful thing any club can take from it is exactly what it looks like to never need one.

Section 65 of the Football Governance Act 2025 is the Independent Football Regulator's most fundamental information-gathering power, and it is also the one most likely to arrive at a club without any warning that an investigation is under way. Unlike the expert reporter power under section 66, which involves the IFR commissioning an independent third party, section 65 is the IFR's own direct power to require any person to hand over, generate or even collect information it does not currently hold. Understanding exactly what a notice under this section can require, and what happens if a club gets its response wrong, matters to every regulated club, not only those already facing a live enquiry.

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.

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.