IFR Expert Reporter: What Section 66 Means for 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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What section 66 actually says

Section 66 sits within Part 7 of the Football Governance Act 2025, the part of the Act dealing with the IFR's information-gathering powers. It gives the IFR the power to appoint an expert reporter, an independent person the IFR nominates, to prepare and provide the IFR with a report in relation to a regulated club, where the IFR considers that a report on the matter is necessary for the purpose of exercising its functions under the Act. This is, in substance, the IFR commissioning its own independent report into a specific issue at a specific club, carried out by someone the IFR has chosen, not the club.

Once appointed, the expert reporter has meaningful powers of their own. Under section 66(4), the expert reporter may issue their own information notices, requiring any person, not only the club itself, to give specified information where the expert reporter considers it necessary for preparing the report. Those notices must state the timing or frequency with which information must be provided, the place or manner (which may be remote) in which it must be given, and the form it must take. This is not an informal request for cooperation. It is a formal information-gathering power exercised on the IFR's behalf.

The IFR's wider investigatory toolkit also includes warrant-based premises powers under Schedule 8. Section 66 sits within that same broader information-gathering architecture, but it is worth being precise: it is the specific power to commission an independent expert's report on a defined matter, not a general audit power exercised by IFR staff directly.

Expert Reporter Power Callout

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The IFR is not merely asking the club for information. It can appoint an expert reporter to prepare a report, with the power to require information from anyone where necessary for that report.

Who pays, and why that matters

One detail in the expert reporter provision deserves particular attention because it changes the practical stakes of an appointment considerably: section 66 creates potential cost exposure. The Act allows the IFR to make rules providing for costs incurred by the IFR in appointing an expert reporter, or expenses incurred by the expert reporter in preparing the report, to be payable by the club concerned. That is different from saying every appointment is automatically charged to the club, but it is enough for clubs to treat an expert reporter appointment as a potential financial exposure from the outset.

This cost-bearing structure is a deliberate design choice that mirrors similar mechanisms in other UK regulatory regimes, and it has a specific behavioural logic: it is intended to concentrate the club's own mind on resolving underlying issues before they reach the point of warranting an independent report, rather than treating regulatory engagement as a cost-free exercise for the club and a resource-intensive one only for the regulator.

The distinction that matters most: expert reporter versus skilled person

The single most common point of confusion in commentary on the Act, and the reason this article exists, is the conflation of the expert reporter power under section 66 with the separate skilled person power under Schedule 9 of the Act. They serve genuinely different functions, are triggered at different points, and clubs preparing for IFR engagement need to understand exactly which one they might be facing.

An expert reporter is an information-gathering and report-preparation tool. It can be deployed where the IFR considers a report is necessary for exercising its functions, which does not require the IFR to have already determined that any infringement has occurred. It is, in effect, a tool the IFR can use to find out what is actually happening at a club on a specific matter, potentially before any conclusion has been reached about whether there is a problem at all.

A skilled person is a remedial tool, available only after the IFR has already determined, whether as a result of an investigation or otherwise, that a club has, without reasonable excuse, committed a relevant infringement, and that the infringement is continuing. The IFR may then require the club to appoint a person the IFR nominates to help the club bring that specific, already-established infringement to an end. Where an expert reporter answers the question "what is happening here?", a skilled person answers the question "how do we fix what we have already found?"

The practical sequence, in many cases, is likely to run in that order: an expert reporter investigates a concern, the IFR reaches a determination on the basis of that report (among other evidence), and, if a continuing relevant infringement is confirmed, a skilled person is then appointed to help resolve it. A club facing an expert reporter appointment should understand that this is very often the earlier stage of a process, not a one-off event, and that how the club engages with the expert reporter can materially affect whether the process ever reaches the skilled person stage at all.

Obstructing Expert Reporter Box

Obstructing an expert reporter is itself a relevant infringement

Schedule 7 of the Act -- which defines what constitutes a relevant infringement -- makes clear that a club commits a relevant infringement if it fails to co-operate with or assist, or otherwise obstructs, an expert reporter appointed under section 66. This sits alongside the equivalent obligation not to obstruct a court-appointed officer or a trustee appointed under the Act\'s enforcement provisions.

This means a club under investigation by an expert reporter faces two separate and cumulative risks: whatever the underlying matter under investigation turns out to reveal, and a freestanding infringement -- which may expose the club to a financial penalty if the IFR takes action, subject to the statutory caps in Schedule 9 -- if the club fails to cooperate with the reporter\'s information requests, misses the timing or form requirements the reporter specifies, or otherwise makes the reporter\'s work more difficult than it needs to be. Obstruction is not a clever way to slow a process down. It is a second, independent compliance failure layered on top of whatever prompted the appointment in the first place.

What genuine cooperation with an expert reporter looks like

For a club that receives notice of an expert reporter appointment, the practical priorities are specific and worth setting out clearly, because the obligations under section 66(4) go beyond simply answering questions when asked.

Treat the reporter's information notices with the same seriousness as an IFR notice directly. An expert reporter's information notice under section 66(4) carries the same underlying statutory force as an IFR information notice. The specified timing, format and manner of response are not suggestions -- they are the terms of a formal information-gathering exercise, and failing to meet them is itself the obstruction risk described above.

Understand that the notice power extends beyond the club itself. Section 66(4) allows the expert reporter to require information from any person, not only the club under review. Individual owners, officers, senior managers and, potentially, third parties connected to the matter under investigation may receive their own notices. A club's governance function should be alert to this and should not assume that managing the club's own response is sufficient if individuals connected to the club are approached separately.

Plan for the cost, not just the process. Given that section 66 allows the IFR to make rules for relevant costs or expenses to be payable by the club, the financial exposure of an expert reporter appointment should be treated as a genuine budget line from the moment notice is received, not an afterthought once the report is delivered.

Assume the report may inform a subsequent determination. Because an expert reporter's findings can feed directly into whether the IFR goes on to determine that a relevant infringement has occurred -- and, if so, whether a skilled person is subsequently required -- the quality and completeness of the club's engagement during the expert reporter phase has a direct bearing on everything that follows. This is not a phase to treat as a formality before the "real" process begins. It frequently is the real process.

For a detailed look at what happens once the IFR has determined a relevant infringement has occurred and requires a club to appoint a skilled person, see Lagom's companion article on that specific mechanism. For the full picture of what happens if an IFR decision -- including a determination arising from an expert reporter's findings, is refused or needs to be challenged, see Lagom's guide to the IFR's internal review and appeals process.

An expert reporter appointment is a live regulatory moment, not a formality. How a club responds to it shapes what happens next.

Understanding an IFR power correctly, and responding to a live notice with the right specialist input, is often a specific and time-pressured need rather than a full engagement. Lagom Sports Compliance offers ad hoc hourly support for exactly this kind of situation: a single booked session to work through how to respond to an expert reporter notice or information request, or a fixed number of hours each month at a discounted rate for clubs that expect to need this kind of input on a recurring basis.

If your club has received notice of an expert reporter appointment or an information request connected to one, get in touch to talk through what that looks like.