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.

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.

Compliance advisers, one independent firm has already observed, are increasingly describing the IFR's Owners, Directors and Senior Executives regime as football's own version of the Senior Managers and Certification Regime -- the framework that transformed how UK financial services firms recruit, promote, monitor and exit senior staff. That comparison is instructive, not just clever. Financial services HR teams spent years learning, often the hard way, that a personnel-level regulatory regime cannot sit solely with legal or compliance. Football HR teams are now in exactly that position, and most have not yet had the equivalent conversation.

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.