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.
What section 65 actually says
Section 65 sits at the start of Part 7 of the Football Governance Act 2025, the part of the Act dealing with the IFR's information-gathering powers, and it is the foundation the rest of that Part builds on. It gives the IFR the power to give a person an information notice requiring that person to give specified information to the IFR, wherever the IFR considers the information necessary for the purpose of exercising its functions under the Act. This is a direct power, exercised by the IFR itself, not delegated to a third party -- and it is available to the IFR at any time it considers the information necessary, without a prior investigation or a determination that anything has gone wrong.
The Act sets out specific content requirements every information notice must meet. It must explain why the IFR requires the information, state the time by which or the frequency with which it must be given, state the place or the manner -- which may be remote -- in which it must be given, state the required form, and include information about the possible consequences under Part 8 of the Act of not complying. A notice that fails to meet these requirements is not properly constituted, which gives clubs a specific, practical checklist against which to review any notice they receive.
The power goes further than simply asking for existing documents
One feature of section 65 deserves particular attention because it is genuinely more intrusive than a conventional document request, and clubs frequently underestimate its reach. The power under this section does not stop at requiring a person to hand over information they already hold. It expressly includes the power to require the person to obtain or generate information for the specific purpose of giving it to the IFR, and to require the person to collect or retain information they would not otherwise collect or retain, again for the purpose of giving it to the IFR. In practical terms, the IFR is not limited to asking what a club already has on file. It can require the club to go and create records, run an internal exercise, or start tracking something specifically because the IFR has asked for it.
The Act also anticipates the situation where specified information simply does not exist or cannot be located. If a person does not give the IFR information that has been specified in a notice, the IFR can require that person to state, to the best of their knowledge and belief, both where that information actually is and why it has not been given. Silence or a partial response is not, in itself, a way to satisfy the notice.
This is not limited to asking what a club already has on file. The IFR can require a club to go and create the record it wants, specifically because it has asked for it.
No investigation required: a standalone power
It is worth being precise about when section 65 can be used, because it is broader than many clubs assume. Independent commentary on the Act's information-gathering framework has confirmed directly that the IFR has standalone powers to request information without any active investigation. A section 65 notice does not signal, by itself, that the IFR suspects wrongdoing or has opened a formal enquiry into a specific matter. It can be, and often will be, a routine exercise of the IFR's ordinary supervisory functions -- checking in on a specific aspect of a club's position, verifying something submitted as part of a licence application, or gathering sector-wide information as part of the IFR's broader regulatory work.
This matters because it changes how a club should read the arrival of a notice. An information notice under section 65 is not automatically a signal of trouble, and clubs should resist the instinct to treat every request as evidence that an investigation is already under way. At the same time, the IFR's own practice, where practicable, is to share a draft of an information notice with the intended recipient to discuss matters such as deadlines before issuing the final version -- which gives clubs a genuine, practical opportunity to engage constructively on the scope and timing of a request before it becomes formally binding, rather than only after the fact.
The distinction that matters most: section 65 versus section 66
Lagom's companion article on the IFR's expert reporter power addressed a common point of confusion in commentary on the Act: conflating the expert reporter power under section 66 with the remedial skilled person power under Schedule 9. Section 65 sits at a different point in that same picture, and deserves its own clear distinction from section 66 specifically.
Section 65 is the IFR's own general, standalone information-gathering power. The IFR itself issues the notice, directly to any person, and can do so at any time it considers information necessary for its functions -- with no requirement for an active investigation, and no third party involved in gathering the information.
Section 66 is narrower and more specific. It allows the IFR to appoint an independent expert reporter to prepare a report on a defined matter, and that reporter then has their own separate information-notice power under section 66(4), exercised on the IFR's behalf rather than by the IFR directly. Where section 65 is the IFR asking a question itself, section 66 is the IFR commissioning someone else to go and find the answer.
In practice, the two powers can and do work together. A section 65 notice might be the IFR's first step in understanding a matter; if what comes back raises a more complex or technical question requiring dedicated investigation, the IFR may then move to appoint an expert reporter under section 66 to go further. A club that treats a section 65 notice as the whole of a potential enquiry, rather than a possible first stage of one, is not seeing the full picture.
What happens if a club does not comply
Non-compliance with a section 65 notice is dealt with through a specific route under the Act. Section 75 provides that where the IFR determines, without reasonable excuse, that a person has failed to comply with an ‘information requirement’ -- a term the Act defines to include requirements imposed under section 65, section 66, section 72, or Schedule 8 -- Part 1 of Schedule 9 sets out the action the IFR may take. Confirmed sanctions include public censure and financial penalties, which for a club can reach up to 10% of global revenue.
In the most serious cases, wilfully or recklessly withholding information from the IFR, or misleading it, can constitute a criminal offence under section 78 of the Act -- separate from, and in addition to, the civil sanctions available under Schedule 9. The Act does not carve out an exemption for commercially sensitive or confidential information from the scope of a notice, though the IFR is required to treat any such information confidentially and not use it for any unrelated purpose. A club that receives a section 65 notice and is tempted to treat parts of its response as beyond the IFR\'s reach on confidentiality grounds should understand that this is not, in itself, a valid basis for non-compliance.
What genuine compliance with a section 65 notice looks like
For a club that receives an information notice, the practical priorities go beyond simply answering the specific questions asked.
Check the notice against the Act's own content requirements. A properly constituted notice must explain why the information is required, specify the deadline or frequency, specify how and where the information must be provided, specify the required form, and set out the consequences of non-compliance. A club that receives a notice missing any of these elements has a legitimate, specific basis to query it before responding.
Do not assume the request is limited to existing records. Because the power extends to requiring a club to generate new information or to start collecting and retaining information it would not otherwise keep, a club should read a notice carefully for exactly what is being asked, rather than assuming a search of existing files will necessarily satisfy it.
Engage on scope and timing where a draft is shared. Given the IFR's stated practice of sharing draft notices where practicable, a club should treat that engagement window as a genuine opportunity, raising legitimate questions about deadlines or scope constructively and early, rather than waiting until a final notice has already been issued.
Never treat silence or a partial answer as a safe default. Where information genuinely cannot be provided, the Act requires a specific, good-faith explanation of where it is and why it has not been given -- not simply an absence of response. Clubs should build this into their own internal process for handling notices from the outset.
For the detail of the IFR's related power to appoint an independent expert reporter under section 66, and how that power differs from the remedial skilled person mechanism, see Lagom's companion article on section 66. For what happens where the IFR's information-gathering leads to an adverse determination, and how that decision can be reviewed or appealed, see Lagom's guide to the IFR's licence refusal and appeals process.
An information notice is not a formality to file away. It is a live regulatory exercise with real consequences for getting the response wrong.
Lagom Sports Compliance is the UK's specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. We support clubs across three connected areas relevant to this kind of regulatory engagement: IFR licensing support, helping clubs build the underlying evidence base and governance capability that reduces the likelihood of an information notice ever surfacing a genuine gap; an ongoing retainer for clubs that want continuous, specialist oversight of their IFR relationship rather than reactive support only once a notice arrives; and M&A due diligence for clubs and investors evaluating a transaction, where a target club's regulatory history and its handling of IFR information requests is itself a genuine diligence question. If your club has received an information notice, or wants to strengthen its position before one arrives, get in touch to talk through what that looks like.
Frequently asked questions: the IFR's section 65 information notice power
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An information notice is a formal notice the Independent Football Regulator can give to any person, under section 65 of the Football Governance Act 2025, requiring that person to provide specified information the IFR considers necessary for exercising its functions under the Act. It must explain why the information is required, specify the deadline or frequency, specify the manner and form of provision, and set out the consequences under Part 8 of the Act for non-compliance.
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No. Section 65 is a standalone power the IFR can use without any active investigation into a specific club or individual. Independent commentary on the Act has confirmed the IFR has standalone powers to request information as part of its ordinary supervisory functions, separate from any formal enquiry into suspected wrongdoing. Receiving a notice under section 65 does not, by itself, mean a club is under investigation.
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Yes. The power under section 65 explicitly extends beyond requiring existing information to be handed over. It includes the power to require a person to obtain or generate information for the specific purpose of giving it to the IFR, and to require a person to collect or retain information they would not otherwise collect or retain, again for the purpose of providing it to the IFR. This is a materially more intrusive power than a conventional document request.
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Section 65 is the IFR's own general, standalone power to require information directly from any person, exercised by the IFR itself and available without a prior investigation. Section 66 is a narrower power allowing the IFR to appoint an independent expert reporter to prepare a report on a specific matter, with that reporter then holding a separate information-notice power under section 66(4) exercised on the IFR's behalf. In practice, a section 65 notice can precede, and inform the IFR's decision to move to, a section 66 expert reporter appointment for a more complex matter.
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Under section 75 of the Act, where the IFR determines, without reasonable excuse, that a person has failed to comply with an information requirement -- a term that includes requirements under section 65 -- Part 1 of Schedule 9 sets out the available sanctions, which include public censure and financial penalties of up to 10% of global revenue for a club. In the most serious cases, wilfully or recklessly withholding information from the IFR or misleading it can constitute a separate criminal offence under section 78 of the Act.
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No. The Act does not provide an exemption for commercially sensitive or confidential information from the scope of a section 65 notice. However, the IFR is required to treat any such information it receives confidentially and must not use it for any purpose unrelated to exercising its functions under the Act. Commercial sensitivity is not, by itself, a valid basis for non-compliance with a properly issued notice.