If I Were a Club CEO, This Is What Would Worry Me About IFR

Hello, my name is Jonathan Greenstein and I am one of the co-founders of Lagom Sports Compliance. Typically, I write about, and talk to club C-suite about, the Independent Football Regulator for a living. As a consultancy --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.

This article has been drafted following conversations with English club c-suite where I have collated views into one document.

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The part that is about me, not just the club

I would start with the thing most CEOs still underestimate, because it is genuinely new: the IFR is not just assessing my club. It is assessing me. As Chief Executive, I hold SMF2 under the ODSE regime -- one of six Specified Senior Management Functions the Regulator tests individually, on my own honesty and integrity, my own financial soundness, and my own competence to do this job. That is not a corporate filing exercise I can delegate to legal or hand off to a compliance function and forget about. It is a personal determination, made about me, that sits on a public register.

What would genuinely worry me is not the initial application. It is what happens afterward. My suitability is not a certificate I earn once and keep forever. Section 34 of the Act gives the IFR the power to revisit it at any point I remain in post, and section 33 places a duty on both me and the club to notify the Regulator if there is a material change in circumstances relevant to my own suitability. I would want to know, with real precision, what counts as material -- because getting that judgement wrong, in either direction, is itself a risk I am now personally carrying that did not exist for my predecessor in this role five years ago.

IFR Assessing Me Callout

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The IFR is not just assessing my club. It is assessing me. That is the part most CEOs still have not fully absorbed.

What it means for the club itself

Then there is the club. I would be thinking about six criteria at once, and honestly, the one I would worry about most is not the one with the biggest number attached to it. Financial resilience gets the headline attention -- audited accounts, revenue thresholds, a documented financial sustainability plan -- and it is genuinely demanding. But it is also, in a strange way, the criterion I would feel most confident about, because my finance director already speaks that language fluently.

What I would actually worry about is governance, because it is judged on something much harder to fake than a balance sheet: evidence of how the club actually operates, not what the policy documents say it should do. Board minutes that show genuine debate, not rubber-stamping. Delegation of authority that is real, not decorative. A conflicts of interest process that has actually been used, not just written down. I know, from years of sitting in boardrooms, exactly how much distance can exist between a governance framework that looks complete on paper and one that would survive someone actually asking hard questions about it. That distance is precisely what the IFR is now positioned to find.

And I would worry about the compounding effect of a genuine gap being found. A skilled person appointment -- someone the IFR nominates, not someone I choose, at the club's cost -- exists specifically for continuing infringements the Regulator judges I have not fixed without reasonable excuse. Financial penalties can reach 10% of total club revenue. A licence can, in the most serious cases, be suspended or revoked. None of that happens overnight, and none of it happens without warning. But I would want to know, honestly, whether my club is the kind of organisation that treats an early warning as exactly that -- or the kind that waits until the warning becomes a determination.

Leadership Team Worry Box

The specific worry about my own leadership team

It is not just me. My chair holds SMF1. My chief finance officer likely holds SMF3. Depending on how the club is structured, my chief operating officer, other board directors, and potentially a senior figure with real influence over the club\'s affairs even without a formal title -- caught by the SMF6 catch-all -- are all individually in scope too.

What would genuinely worry me is not any one of those individuals failing their own determination. It is the possibility that I have never actually asked the question at leadership level: have we, as a group, mapped who in this organisation is actually caught by ODSE, and are we confident every one of them would clear the bar if the IFR looked closely today? That is a conversation I suspect most boards have not yet had properly, and it is not a conversation I would want to be having for the first time after a notice has already arrived.

What it means for my staff

Beyond my own leadership team, I would be thinking hard about the people actually doing the work of proving all this. Someone has to gather the evidence, maintain the financial plan, document the governance framework, keep the fan engagement records current, and respond when the IFR asks a question. In a Premier League club, that might already be a dedicated compliance function. Further down the pyramid, it is very often a general counsel, a company secretary, or a finance team member who has just acquired a substantial new workload on top of an existing job, without necessarily having been given the resource, training or authority to do it properly.

That is what would worry me about my own staff specifically: not that they are incapable, but that I might be asking them to build something genuinely new -- an evidenced, defensible compliance function -- without having honestly resourced it. A licensing regime that lands on overstretched people, with no additional capacity and no clear ownership, is a regime that gets satisfied on paper and fails in practice. I have seen that pattern in enough other sectors to know exactly how it ends.

What it means for my players

Players do not sit within the ODSE regime directly, and I would not want to overstate their personal exposure. But I would be thinking about two specific ways this reaches the football side of the business regardless.

First, the financial resilience and governance conditions are not abstract to a recruitment strategy. A financial plan the IFR has scrutinised, and a squad cost position UEFA is independently watching if we are in European competition, both directly constrain what I can actually commit to in a transfer window -- wages, transfer fees, agent commissions, all of it. I would want my head of recruitment thinking about regulatory headroom in the same conversation as scouting reports, not as an afterthought raised by finance once a deal is already agreed.

Second, I would be acutely aware that our own internal systems, the ones processing registration paperwork, now sit inside a genuinely unforgiving external deadline structure. A transfer window that closes at a fixed hour does not extend itself because our systems had a bad day. That is an operational resilience question as much as a compliance one, and it is exactly the kind of dependency I would want tested before deadline day, not discovered on it.

What it means for our fans

This is the one I suspect most CEOs still underrate. The fan engagement condition is not a communications exercise. It requires genuine, structured, documented consultation -- evidence that supporter views are actually sought, actually considered, and actually reflected in how decisions get made, not a newsletter dressed up as engagement.

What would worry me here is specific: I know, better than most, how easy it is for a club to believe its own fan relationship is strong because attendance is good and the shirt sells well, while having no genuine, evidenced consultation process behind any of the decisions that actually matter to supporters. The IFR is not testing whether fans like the club. It is testing whether the club can prove it listens. Those are not the same thing, and I suspect the gap between them is wider at my own club than I would like to admit before I actually went looking for it.

What I would actually do about all of this

None of the above is a reason to panic, and I would be careful not to let it become one. It is a reason to be honest, early, about where the genuine gaps sit -- in my own personal position, in my leadership team's collective readiness, in how my staff are resourced, in how recruitment decisions account for regulatory headroom, and in whether our fan engagement would actually survive being tested rather than assumed.

If I were sitting in that chair today, the single thing I would prioritise is turning each of those open questions into an answer I could actually evidence -- before a notice, an information request, or a determination forces me to find the answer under pressure instead.

Every CEO reading this is already living some version of the concerns above. The only real choice is whether you find your own answers now, or discover them under regulatory pressure later.

Lagom Sports Compliance supports club CEOs and their leadership teams across both IFR licensing and the ODSE regime, at a level genuinely proportionate to where you actually stand. For licensing, we offer:

Review Only support for clubs preparing their own application who want an independent, criterion-by-criterion review before submission;
Part Support for clubs that want to lead certain work-streams while we own others; and
Full Support, where a named senior consultant leads the entire licensing project from readiness assessment through to post-submission.

For ODSE specifically, we help CEOs and their leadership teams map exactly who in the organisation is in scope, assess individual readiness against the fitness and source of wealth tests, and build the material change notification process that keeps you compliant for as long as you hold the role, not just at the point of your original determination. If any of the concerns above sound genuinely familiar, get in touch and we will talk through what the right level of support looks like for your specific position.

We have also built a self service IFR readiness assessment tool. It takes around 15 minutes to complete and gives you a guide as to what you may need to, based on what you already have in place.