What Football HR Teams Should Know About the ODSE Regime

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.

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Why this lands on HR's desk, not just compliance's

The ODSE regime tests individuals -- their honesty and integrity, their financial soundness, and for Specified Senior Management Function holders specifically, their requisite competence -- before they can take up, or continue in, an owner or senior management role at a regulated club. That is a personnel decision wearing regulatory clothing. Every stage of the process it creates -- who gets identified as being in scope, how their application is prepared and evidenced, what happens when someone is promoted into a new function, what happens when they leave -- runs directly through the same processes HR already owns for every other role in the club.

The parallel with financial services is genuinely useful here, and it is worth being precise about why. Under the Senior Managers and Certification Regime, HR teams learned that a regime testing individuals for fitness and propriety changes recruitment, onboarding, promotion and exit processes fundamentally -- not as an add-on project, but as a permanent feature of how those processes now have to work. ODSE is asking English football's HR functions to make the same adjustment, on a considerably faster timeline than financial services was given.

Personnel Level Regime Callout

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A personnel-level regulatory regime cannot sit solely with legal or compliance. Football HR teams are now exactly where financial services HR teams were a decade ago.

The timeline HR needs to understand, because it is not one date

It is worth being precise about the ODSE regime's actual rollout, because treating it as a single deadline understates what has already happened and what HR teams need to be doing right now. The IFR's powers to investigate incumbent owners, directors and senior executives -- individuals already in post -- were formally activated on 12 December 2025. From 5 May 2026, the regime extended further: every prospective owner and senior manager must clear the ODSE test before taking up their role. That second date is the one most relevant to HR's day-to-day recruitment process, and it means the regime has been operationally live for new appointments since that point, not something still on the horizon.

Recruitment Timeline Number Box

The recruitment timeline number every HR team should already have in their process

The IFR has a statutory window of 90 days from a complete application to reach a determination, extendable to 150 days in exceptional circumstances. Independent advisory commentary has already flagged the practical consequence directly: the approval process may take up to five months, and clubs should be seeking regulatory clearance earlier in the recruitment process than IFR guidance currently suggests, rather than treating it as a final step before completion.

For HR, this is a genuinely operational finding, not an abstract one: a senior appointment process that only initiates ODSE engagement once a candidate has accepted an offer is very likely building in months of delay the business has not planned for. That conversation needs to happen with recruiting managers and, ideally, candidates themselves, considerably earlier in the process than has traditionally been the norm for a senior football appointment.

Mapping who is actually in scope and why SMF6 is the hard part

ODSE applies to owners holding more than 25% of shares, voting rights or equivalent influence, and to individuals holding one of the six Specified Senior Management Functions. Five of those six are relatively straightforward to map against an organisational chart -- Chair, Chief Executive, Chief Finance, Chief Operations, and Director more generally. The sixth, SMF6, covers any individual with significant and continued influence over one or more aspects of the club's activities, regardless of formal job title.

This is the category HR most needs to own carefully, and it is worth being honest that the regime itself has not yet fully settled its own boundaries here. At least one industry stakeholder response to the IFR's own consultation has specifically criticised the "significant influence" test as too vague, calling for a PRA-style illustrative, non-exhaustive list of roles and circumstances the way UK financial regulators provide for their own equivalent catch-all category. The IFR has not, as things stand, published that kind of list. Until it does, mapping who genuinely falls within SMF6 at a specific club is a judgement exercise, not a mechanical one -- and HR is very often the function with the clearest, most accurate picture of who actually exercises influence over club decisions, regardless of what a job title says.

Ongoing monitoring: material change is an event, not an annual cycle

This is one of the clearest points of genuine divergence from the SMCR comparison, and HR teams should understand it precisely rather than assume the two regimes work identically. Financial services' Certification Regime requires firms to re-certify covered individuals' fitness and propriety at least annually -- a scheduled, recurring cycle HR can build a calendar around. ODSE, as currently constituted, does not impose an equivalent annual re-attestation requirement. Instead, incumbent owners and officers must notify the IFR of any material change in circumstances -- confirmed examples include a new criminal conviction or bankruptcy -- as soon as reasonably practicable after it occurs.

That is an event-driven obligation, not a calendar-driven one, and it changes what HR needs to build. Rather than a single annual reattestation exercise, the club needs a live, ongoing process capable of actually surfacing a material change when it happens -- which depends heavily on HR's own visibility into the personal and professional circumstances of the individuals concerned, and a clear, well-understood internal escalation route when something relevant comes to light. It is worth noting, too, that at least one stakeholder response has proposed the IFR move toward exactly the kind of annual attestation cycle SMCR uses. Whether the regime evolves in that direction is genuinely open -- HR teams should build a process robust enough to handle whichever direction the requirement ultimately takes, rather than assuming the current event-driven model is necessarily permanent.

Role changes, promotions and the club's own growth

A promotion into a role that carries SMF status -- a Head of Football Operations stepping up into a role that now meets the SMF6 threshold, an interim Chief Finance appointment becoming permanent -- triggers the same regulatory engagement a completely new external hire would. HR processes built only around the assumption that ODSE applies to external recruitment specifically will miss this. Internal promotion and succession planning discussions now need an ODSE checkpoint built in, at the point a role change is being considered, not after it has already been announced internally.

There is a specific, useful piece of good news for clubs moving between tiers: owners and managers at a club promoted from the National League North or South are treated as incumbents rather than facing immediate re-approval, consistent with the same incumbent treatment that applied when the regime first went live. HR teams at clubs with realistic promotion prospects should understand this distinction, since it materially affects the compliance workload a promotion actually creates.

Exit processes: an area worth watching, not yet fully mapped

Financial services' SMCR imposes a detailed regulatory reference regime on exit -- new employers must request, and previous employers must provide, references covering up to six years of conduct history, with no time limit on notifying a former employer of serious misconduct discovered after someone has left. It would be a mistake to assume ODSE currently mirrors this in detail; there is, at the time of writing, no confirmed equivalent formal reference regime published for departing SMF holders at football clubs.

That does not mean exit is unimportant for HR to think about now. When an individual holding an SMF role, or a qualifying ownership stake, leaves the club, that is itself a change in the club's own regulatory position -- the role needs a plan for temporary or permanent cover, and the IFR's temporary appointments provision (a 12-week window for unforeseen absences in an SMF role, still being finalised through IFR consultation as this article is written) is directly relevant to how HR should plan for unplanned departures specifically. Building a clear internal process for this now, even in the absence of a fully mature exit framework from the regulator, puts HR ahead of a requirement that is very plausibly still being built out.

HR's role in actually leading this, not just administering it

The lesson financial services HR teams learned, and one worth applying directly here: the function most likely to succeed with a regime like this is the one that reads the actual rules itself, rather than waiting for a summary from compliance. Understanding the ODSE regime's specific mechanics -- who is in scope, what the timeline actually requires, what counts as a material change -- puts HR in a position to lead recruiting managers and the club's own leadership through the process, rather than reacting to it after a compliance team has already identified a problem.

That leadership role includes building genuine organisational awareness of what ODSE actually requires -- not a single training session delivered once and never repeated, but ongoing communication with the people actually making senior hiring and promotion decisions, so that regulatory engagement is planned into the process from the outset rather than discovered as a delay once an offer has already been made.

For the full detail of the ODSE regime and the six Specified Senior Management Functions, see Lagom's existing complete guide to the ODSE regime.

ODSE is not a document HR files once. It is a permanent feature of how recruitment, promotion and succession planning now have to work.

Lagom Sports Compliance supports clubs and HR teams through the full ODSE process -- from mapping who is actually in scope, including the genuinely difficult SMF6 judgement calls, through to building recruitment and promotion processes that account for the IFR's real approval timelines. For the complete picture of our IFR compliance support for English football clubs, including governance framework design and ODSE compliance and approval support, see our services page. We also run a free ODSE training session built specifically for the people, including HR and people leaders, who need to understand what the regime actually requires without wading through the statute themselves.