IFR Licence Refused or Appealed: A practical guide to the decision-making process

Most of the published guidance on the Independent Football Regulator's licensing regime, including Lagom Sports Compliance’s own, explains how to apply, what the Threshold Requirements ask for, and what a club's evidence pack needs to contain. Almost none of it explains what actually happens if the application does not succeed. Given that the consequence of an unresolved refusal is a club being unable to operate a team in a specified competition, that is a significant gap. This article closes it.

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The decision-making body and the statutory clock

The IFR's power to grant or refuse an operating licence sits within a specific procedural framework set out in the Football Governance Act 2025 and the IFR's own rules made under Part 4 and section 90 of the Act. Once a club has submitted a provisional licence application, the IFR must first determine whether the application is complete -- a specific procedural gate under Rule C4 of the IFR's rules, distinct from the substantive merits assessment that follows.

Once an application is treated as complete, a statutory clock starts running. Under Rules C5.1 and C5.2, the IFR has three months from the point of completeness to make its decision, with the ability to extend that period by a further one month in defined circumstances. The substantive question the IFR is answering within that window is set out in section 17(2) of the Act -- whether the club has demonstrated, to the required standard, the matters the provisional licence test requires. A refusal at this stage is not a discretionary judgement call made informally; it is a reasoned determination against a specific statutory test, and the IFR is required to give reasons for it.

Refusal Reasoned Determination Callout

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A refusal is not an informal judgement call. It is a reasoned determination against a specific statutory test, and the IFR must give its reasons in writing.

Grounds for refusal: what actually causes a licence to be refused

It is worth being precise about what triggers refusal at each stage of a club's journey through the licensing regime, because the grounds differ materially between the provisional and full licence stages.

At the provisional licence stage, refusal follows from a determination that the club has not demonstrated the matters required under section 17(2) -- broadly, the threshold evidence the IFR requires before authorising a club to operate on even a provisional basis. Given that every club within the IFR's scope is expected to hold a provisional licence as the baseline position, a refusal at this stage is a serious and unusual outcome, reserved for cases where the fundamental evidence required simply has not been provided or does not meet the required standard.
At the full licence stage, the test is broader: the club must be operating a relevant team, must meet all applicable Threshold Requirements, must be complying with its mandatory licence conditions and any additional duties imposed on it, and must have no unsuitable owner or officer in place. A club that has held a provisional licence for three years, plus any extension granted, without meeting this fuller test faces a specific and severe consequence: the IFR revokes the provisional licence and refuses the full licence together, rather than the two decisions being treated separately.

It is worth noting, based on the IFR's own published policy position, that revocation and refusal are consistently framed as measures of last resort. The IFR has indicated it will usually seek to address concerns through supervisory tools -- engagement, discretionary licence conditions and remediation requirements -- before moving to revocation or refusal. This does not mean refusal cannot happen. It means clubs engaging constructively and transparently with the IFR at the earliest sign of a gap in their evidence are, on the IFR's own stated approach, considerably less likely to reach the point of formal refusal in the first place.

The two routes to challenge a decision

Where the IFR does refuse, revoke or otherwise make a decision a club disagrees with, the Football Governance Act sets out two distinct routes of challenge, and it is important to understand both the sequence and the difference between them.

The Act identifies a defined list of 27 reviewable decisions -- a specific menu set out in the legislation, covering matters including the grant, suspension or revocation of an operating licence, determinations of owner or officer suitability, disqualification orders, and distribution orders, among others. Not every decision the IFR makes is reviewable in this formal sense; the Act is specific about which decisions qualify.

Internal review

A "concerned person" -- defined narrowly in the Act as a person who is directly affected by the decision -- can request an internal review of a reviewable decision, conducted by the IFR's own Board or an Expert Panel independent of the original decision-maker. In practice, this standing threshold will usually limit the right to the club, owner or officer who is the subject of the decision itself. The IFR is not obliged to conduct every review requested: it may decline where the decision is already the subject of a CAT appeal, where the request is vexatious, or where there is no reasonable prospect of the review changing the outcome. Where the IFR proceeds with a review, it has 28 days to carry it out and communicate a reasoned outcome, extendable by a further 14 days in defined circumstances. The standard applied is whether the decision was "materially wrong" -- a deliberately flexible test whose practical meaning will depend on the nature of the decision under review. Critically, requesting an internal review does not automatically suspend the effect of the original decision -- the refusal or revocation remains in force while the review is under way, and for certain categories of decision designed to take immediate effect, even the reviewer's discretion to grant a stay is removed.

External appeal to the Competition Appeal Tribunal

For six categories of decision -- including licence revocation and suitability determinations -- a concerned person may appeal directly to the Competition Appeal Tribunal (the CAT), a specialist judicial body with cross-disciplinary expertise in law, economics, business and accountancy, without going through internal review first. For other categories of decision, such as the imposition of a financial penalty, internal review must be exhausted first before any CAT appeal is available. The CAT's standing threshold is broader than the internal review's: anyone with a "sufficient interest" - the same test as in judicial review - can bring an appeal, which in the football context may extend to supporters' trusts, rival clubs, and other stakeholders with a genuine interest in the outcome. The notice of appeal must be filed within 21 days of notification and must be substantive: it has to set out a summary of the grounds of appeal, succinct arguments supporting each ground, the relief sought, and copies of all evidence relied upon. The standard of review is not uniform: for the 6 high-stakes decisions, the CAT conducts a full merits review and can substitute its own decision; for all other decisions, it applies judicial review principles - legality, rationality and procedural fairness - which is a materially harder bar to clear. As with internal review, lodging a CAT appeal does not automatically suspend the effect of the IFR's decision -- a stay is available only if the CAT specifically orders one, and for certain categories of decision the Act expressly removes the CAT's power to grant a stay at all.

Alex Harvey, Partner in the Sports Group at Sheridans: "The gap between the standing thresholds for internal review and the CAT is not academic; it determines who gets a voice in the process, and when. A supporters' trust, for example, almost certainly cannot trigger an internal review, but may well have 'sufficient interest' to bring a CAT appeal. Expect the early years of IFR litigation to include genuine battles about who gets to appeal in the first place."

Standard of Review Box

The standard of review matters -- and it is not the same in every case

One of the more technical, but genuinely consequential, features of the appeals framework is that the CAT does not apply the same standard of scrutiny to every case it hears, and clubs preparing for a possible appeal need to understand which standard applies to their specific situation.

For the six high-stakes decisions -- operating licence revocations and suspensions, owner and officer suitability determinations, and disqualification orders -- the CAT conducts a full merits review, whether the decision is challenged at the CAT for the first time or on appeal from an internal review. It steps into the IFR\'s shoes and can reach its own view on whether the original decision was right or wrong on the facts. For all other reviewable decisions, however, the CAT applies judicial review principles -- legality, rationality, and procedural fairness -- asking not whether the decision was correct on the substance, but whether the IFR made a legal or procedural error serious enough to require it to be set aside. This is a materially narrower test and harder threshold to overcome.

Alex Harvey, Partner in the Sports Group at Sheridans: “For decisions where internal review is mandatory before any CAT appeal, the quality of the internal review submission is critical. The CAT will not re-examine the substance of the decision from scratch - it will only ask whether the IFR acted lawfully, rationally, and fairly. That means a weak or poorly prepared internal review submission cannot be rescued on appeal.”

The interim operational position while an appeal is live

This is the question that matters most in practice, and it is worth stating plainly: neither requesting an internal review nor lodging a CAT appeal automatically pauses the effect of the IFR's original decision. A club whose licence has been refused or revoked remains, in the absence of a specific stay, in that position while the review or appeal is under way.

For a licence refusal or revocation specifically, this is the sharpest possible illustration of why proactive engagement with the IFR long before a final decision is made matters more than the strength of any subsequent appeal. The IFR's own stated approach -- addressing concerns through supervisory tools before reaching revocation or refusal -- means clubs typically have visibility of concerns well in advance of a final adverse decision. It is also worth noting that where a mid-season revocation or suspension does occur, the IFR's framework provides that it takes effect from the end of the season rather than immediately -- a specific mitigation clearly designed to avoid a club being forced out of live competition mid-fixture-list, though this does not remove the underlying seriousness of the decision or the need to resolve it.

For clubs facing this position, the practical question becomes: what evidence, submitted at the review or appeal stage, could plausibly change the outcome, and is that evidence being assembled and presented to the standard the internal review or the CAT will actually apply -- merits-based or judicial-review-based, depending on the route. A generic restatement of the original application is unlikely to succeed under either standard. What tends to matter is specific, new or clarified evidence addressing precisely the gap the IFR identified in its original reasons for refusal.

Beyond the Competition Appeal Tribunal

A further appeal from a CAT decision is potentially available to the Court of Appeal, but only on a point of law, and only with permission -- either from the CAT itself or from the Court of Appeal directly. This is a narrow route, reserved for cases where the CAT is said to have applied the law incorrectly, rather than a further opportunity to re-argue the facts. For most clubs, the internal review and CAT stages will represent the practical entirety of the available challenge process.

The Act is largely silent on costs at the internal review stage, though it permits the IFR to make rules requiring a person who requested a review to bear the IFR's costs of conducting it where the original decision is upheld -- a rule clubs should factor into any decision about whether to pursue review speculatively rather than on genuinely strong grounds.

Club Practical Steps Licensing Position Box

What this means practically for a club approaching its own licensing position

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Treat every communication from the IFR expressing concern about a specific requirement as an early warning, not a formality -- the IFR's own stated preference is to resolve issues before reaching refusal or revocation, which means the window to address a gap is usually open well before any final decision.

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If a decision is adverse, establish immediately which of the 27 reviewable decisions it falls under, and which challenge route -- internal review, direct CAT appeal, or internal review followed by CAT appeal -- actually applies to it, since the routes are not identical for every decision type.

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Understand from the outset that neither review nor appeal automatically pauses the decision -- plan the club's operational position on the assumption the original decision remains in force unless and until a stay or a successful outcome is secured.

4

Build any review or appeal submission around the specific standard that will actually be applied to it -- merits-based reconsideration is a different exercise from a judicial-review-standard challenge, and the evidence that succeeds under one may not succeed under the other.

Football Governance Act 2025, Part 9 | Lagom Sports Compliance commentary

This article sits alongside Lagom Sports Compliance's existing guidance on the IFR licensing regime: the provisional licence application process, the procedural obligations clubs must meet, the mandatory licence conditions, and the corporate governance code requirements. Read together, they set out the full picture from initial application through to what happens if a decision does not go the club's way.

A licence refusal is a serious outcome. It is not, in most cases, the end of the process, provided a club understands the process that follows and acts within it.

Lagom Sports Compliance provides dedicated support for clubs at every stage of the IFR licensing journey, from initial readiness assessment through to managing the review and appeals process if a decision does not go as expected. This support is available as a full licensing engagement, or as ad hoc hourly support -- either booked as needed or as a fixed package of hours each month at a discounted rate, for clubs that need specific, targeted input rather than a full engagement. To discuss what the right level of support looks like for your club, see Lagom's IFR compliance support for English football clubs and IFR football club licensing support, or get in touch directly.