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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Regulation & Compliance, Regulatory Update Jonathan Greenstein Regulation & Compliance, Regulatory Update Jonathan Greenstein

Horizon Scanning: Our predictions for the future of football regulation

Football regulation is not being built from a blank page. Almost every mechanism now appearing in the IFR's licensing framework and the EU's approach to football-specific AML has a direct precedent somewhere in financial services regulation over the past fifteen years. That is not a coincidence -- it is the natural result of governments and regulators reaching for tools that have already been tested elsewhere, rather than inventing football-specific ones from scratch. Reading that precedent carefully lets us make some genuinely informed predictions about where football regulation goes next. These are our own views, not confirmed policy, and we have graded our confidence in each one accordingly.

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The IFR's information notice power explained: what section 65 means for football clubs

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.

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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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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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What does it mean to be an SMF at a football club? The IFR's ODSE regime explained

If you hold a senior role at a regulated English football club, or are about to, the Independent Football Regulator may have already assessed you. If not, it will. Since 5 May 2026, every person carrying out one of six Senior Management Functions at a regulated club requires the IFR's prior approval. That approval is personal, not delegable, and the consequences of operating without it are enforceable against you individually.

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Fan engagement under IFR licensing: what English football clubs must do now and why getting it right matters

For most of English football's history, how a club engaged with its supporters was a matter of choice. The Football Governance Act 2025 has ended that. Fan engagement is now a mandatory condition of the IFR operating licence every regulated club must hold. This article explains what the requirement demands, what it does not demand, and why the clubs that treat it as a governance opportunity rather than a compliance burden will emerge from the licensing process in the stronger commercial and reputational position.

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UEFA Club Licensing 2025: what the new Financial Sustainability Regulations require on ownership integrity

Every club that aspires to enter UEFA competition must hold a licence. Every licence depends on satisfying six categories of criteria. Of those six, the legal criteria, and specifically the ownership integrity requirements contained in Articles 63 to 65 of the UEFA Club Licensing and Financial Sustainability Regulations, Edition 2025, are where the compliance burden is most easily underestimated and the consequences of failure are most immediate. This article explains what those requirements actually demand.

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The IFR ODSE regime: who needs approval, what the regulator assesses, and what clubs must do now

The Independent Football Regulator's Owners, Directors and Senior Executives regime came into force on 5 May 2026. It is not a future obligation. It is not a consultation. Every regulated club in the top five tiers of English men's professional football must comply with it now, and most clubs are only beginning to understand what that compliance actually requires.

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