IFR Licensing Guidance: what ongoing licence compliance now means for regulated clubs
The IFR Licensing Guidance is the document that turns a provisional licence into an ongoing compliance relationship. Clubs must submit financial plans, governance statements, fan consultation reports and annual declarations, then keep those submissions accurate as their circumstances change.
Part 2 of Lagom Sports Compliance’s IFR licensing series. This article can be read on its own, but should also be read alongside our articles on the Provisional Licence Application Guidance, the Licensing Rules and the Football Club Corporate Governance Code.
Licensing support: If your club has not yet mapped its evidence against the IFR licensing documents, now is the time to do it. Lagom Sports Compliance supports regulated clubs through Review Only, Part Support and Full Support licensing engagements, from readiness assessment to pre-submission review and post-submission IFR queries.
The licence is not the end of the process. It is the beginning of supervision
The IFR Licensing Guidance explains how clubs should comply with their ongoing licensing obligations once licensed. It should be read alongside the provisional licence application guidance, the draft licence and Mandatory Licence Conditions, reporting templates and the IFR Licensing Rules.
The starting point is clear. From the start of the 2027/28 football season, clubs need a licence from the IFR to participate in the Premier League, Championship, League One, League Two and the National League. Clubs promoted into the National League from National League North and South will also need to enter the licensing regime.
Clubs first apply for a provisional licence, usually lasting up to three years. During that period, the club operates while working towards a full licence. The provisional licence period is not a relaxed period. Clubs must comply with ongoing licence conditions from the date they receive a provisional licence.
That is the central message of the Licensing Guidance. IFR licensing is not a one-off approval. It is a continuing regulatory relationship built around reporting, board approval, transparency, risk management, fan engagement and the ability of the IFR to intervene where risk requires it.
How clubs move from provisional to full licence
After a provisional licence is granted, the club must work towards the full licence test. The IFR will grant a full licence when it is satisfied that the club is operating a relevant team, meets all Threshold Requirements, complies and would continue to comply with the Mandatory Licence Conditions and additional duties, and does not have any owner or senior manager whom the IFR has determined to be unsuitable under Part 4 of the Act.
The IFR cannot grant a full licence until the club has completed at least one round of reporting. That means submitting a financial plan, corporate governance statement, fan consultation report, annual declaration and attestation on non-financial resources. For clubs licensed ahead of the 2027/28 season, the earliest point at which a full licence may be granted is June 2028, after the annual declaration.
If, after three years on a provisional licence, the club has not met the full licence test, the IFR will notify the club. The IFR can extend the provisional licence period if it believes the club would meet the full licence test within a reasonable period. If not, or if after any extension the test is still not met, the IFR will revoke the provisional licence and refuse to grant a full licence.
This gives clubs time, but not unlimited time. The reporting cycle is the evidence trail that takes a club towards a full licence.
The four Mandatory Licence Conditions
Every club on a provisional or full licence must comply with four Mandatory Licence Conditions.
The financial plans condition requires clubs to submit and comply with a financial plan. As a default position, the first financial plan will be submitted in May 2028 and at least annually thereafter. The reporting window is 17 May to 31 May. Clubs must act in accordance with the plan and resubmit material changes to the IFR.
The corporate governance statement condition requires clubs to submit a corporate governance statement by 31 October 2027, or in the year of promotion for clubs subsequently promoted from National League North or South. The statement must explain how the club applies the IFR’s Football Club Corporate Governance Code and what action the club is taking to improve equality, diversity and inclusion. It must be published online and updated every two years from 2029, or after any material change.
The fan consultation condition requires clubs to establish a group of persons to act as fan representatives, elected or appointed, and to carry out regular consultation with them on relevant matters. Clubs must submit an annual fan consultation report by 15 August each year, setting out how they consulted with fans and how they intend to do so in the coming year.
The annual declaration condition requires clubs to submit an annual declaration between 1 May and 1 June each year, using the IFR template. The declaration must also attest whether or not the club has appropriate non-financial resources.
The three Threshold Requirements
The Threshold Requirements are the standards clubs must meet before the IFR can grant a full licence and continue to meet once on a full licence.
The first is appropriate financial resources. Clubs must have financial resources appropriate to their individual circumstances. They demonstrate this by submitting financial plans and other required financial data and by acting in accordance with those plans.
The second is appropriate non-financial resources. This includes human capital, management and governance structures, physical assets, technological resources and intellectual capital relative to the club’s circumstances. Clubs must attest in their annual declaration whether they have appropriate non-financial resources.
The third is fan engagement. Clubs must have adequate and effective means of consulting fans on relevant matters, take fan views into account when making decisions and report annually by 15 August on how they have consulted and engaged with fan representatives.
The important distinction is this: the Mandatory Licence Conditions are ongoing obligations from the point of provisional licence. The Threshold Requirements are the standards the club must meet for full licence and maintain thereafter. In practice, the evidence overlaps. A strong financial plan, governance statement and fan consultation report all help demonstrate threshold compliance.
Appropriate financial resources: financial reality, not accounting presentation
The financial regulation chapter is one of the most important parts of the Licensing Guidance. It states that clubs must hold and maintain appropriate financial resources to reflect the nature of their activities and the risks they face. This is not a binary requirement. The IFR will not set fixed financial limits that apply to every club regardless of size, financial model or risk. It expects a risk-based approach.
The IFR defines financial resources by reference to the total amount and quality of funding from equity and debt, assets including cash and liquid assets, income streams and financial capacity that the club can reliably access under governance and risk management frameworks.
The guidance is explicit that the IFR does not define appropriate financial resources solely by accounting measures. Profit and loss and balance sheet remain relevant, but non-cash items and accounting adjustments are secondary. The IFR’s primary focus is on actual cash inflows and outflows and the club’s ability to manage adverse scenarios. In the IFR’s words, the focus is financial reality, not accounting presentation.
For club leadership, this means a financial plan cannot simply restate accounts. It must explain liquidity, funding, solvency, risk and management action in a way that reflects how the club actually operates.
The risk factors clubs must assess
The Licensing Guidance identifies four broad risk factors that clubs should consider when determining whether they have appropriate financial resources: business model, liquidity and cash flow, solvency and debt, and governance.
Business model risk arises where there is a funding gap between income and costs. Where a gap exists, clubs must clearly demonstrate how it will be funded. That includes operating deficit, planned investment, income diversity, future costs, liabilities and the reliability of funding sources.
Liquidity and cash flow risk arises where a club cannot access sufficient liquid resources to meet short-term obligations as they fall due. Clubs must hold sufficient liquid assets, manage liquidity risk proactively, prepare accurate and timely cash flow forecasts and monitor actual performance against forecast. Players are not considered liquid assets because their value cannot readily be realised outside transfer windows.
Solvency and debt risk arises where the club’s medium to long-term ability to continue operating sustainably is threatened. The IFR recognises that debt can form part of a club’s business model, including shareholder or soft loans, but expects debt to be well-managed and not to place an undue burden on the club.
Governance risk arises where shortcomings in governance, financial oversight or risk management expose the club to financial or operational vulnerability. Poor board information, weak cash controls, unclear group structures, inadequate financial capability and ineffective risk reporting are all relevant.
Financial plans must include stress tests and mitigation plans
Financial plans must be forward-looking and demonstrate how the club is financially sound under normal operating conditions and resilient in adverse scenarios. The IFR identifies three core stress scenarios: a 10% reduction in annual income, relegation and, where the club relies on external funding to cover deficits, removal of the club’s main source of external funding. Clubs that do not rely on external funding to cover deficits should discuss this with their supervisor and document why that scenario is not required.
The 10% income shock applies to all income sources, not selectively. Relegation analysis should consider broadcasting, matchday and commercial income, costs including wages and matchday costs, and external funding availability, cost and terms. Removal of main source of funding applies where the club relies on external funding to cover deficits and assumes the next forecast funding amount is not received and no further funding is received from that source for the remainder of the period.
The plan must also include stress mitigation plans. These should be realistic, relevant to the shock and sufficiently detailed to be used by the club and scrutinised by the IFR. Possible mitigations include reducing costs, securing financing, securing funding and, where appropriate, player trading.
Player trading may be included in baseline forecasts, used as a management action or included as stress mitigation, but the IFR expects assumptions to be realistic, conservative and supported by evidence. It would not expect player trading to be the sole mitigation for a club significantly affected by removal of its main external funding source.
Acting in accordance with the financial plan
The financial plan is not a static forecast filed once a year and forgotten. Clubs must act in accordance with the latest financial plan submitted to the IFR.
The IFR recognises that forecasts will not be perfectly accurate. Clubs operate in a dynamic environment and actual outcomes may differ. Differences will not automatically mean the club is not acting in accordance with its plan, provided they do not adversely affect financial sustainability or the overall risk profile.
However, where a deviation means the plan becomes materially inaccurate and no longer reflects the club’s risk profile or ability to maintain appropriate financial resources, this is a material change in circumstances. The club must notify the IFR and update and resubmit its financial plan as soon as reasonably practicable.
The guidance gives examples: significant unplanned expenditure or investment, significant unexpected variations in projected income and changes to key funding arrangements or financing commitments. Transfer activity may also become material if aggregate expenditure, income, wage commitments or funding arrangements depart materially from the plan. The IFR does not seek to pre-approve individual transfers. Its interest is the overall financial impact.
Non-financial resources: the board must assess capability, not just cash
The Licensing Guidance defines non-financial resources broadly. They include human capital, management and governance structures, physical assets, technological resources and intellectual capital.
This means clubs must ask whether they have enough skilled people, governance structures, risk controls, facilities, data systems, licences, rights and operational resources to carry on their activities. Where functions or resources are provided by third parties or group companies, responsibility remains with the club or its board. The club should assess whether those arrangements are secure and reliable.
Before a club can be granted a full licence, the board must certify that directors reasonably expect the club to meet and continue to meet the non-financial resources Threshold Requirement. As part of the annual declaration, the club must attest either that the board has assessed the resources and expects them to be sufficient, has assessed them and does not expect them to be sufficient, or has not yet assessed them. The third option is available only while on a provisional licence. A club cannot move to full licence until its board has assessed non-financial resources and certified that they are appropriate.
This is a board governance issue. It requires evidence, minutes, assessment records and a defensible view of operational capability.
Corporate governance statements: apply and explain
The corporate governance chapter explains how clubs should apply the Football Club Corporate Governance Code and submit their corporate governance statements. The Code contains five principles: board, purpose and strategy; risk oversight and controls; board composition and accountability; equality, diversity and inclusion; and stakeholder relationships and engagement.
The Code operates on an apply-and-explain basis. Clubs must clearly explain how they have applied the Code and its principles through their corporate governance statement. Larger, more complex clubs with greater resources are expected to have more developed arrangements and may need more comprehensive statements.
The first statement must be submitted and published by 31 October 2027, with future submissions every two years between 1 August and 31 October. Material changes must be updated, resubmitted and republished as soon as practicable. Examples include significant changes to risk policies, board composition, independence of non-executive directors, constitutional documents or special voting rights.
Statements must be written in plain English, structured clearly and accessible to stakeholders. They must also explain actions the club is taking to improve equality, diversity and inclusion, even where the club is not subject to league or governing body EDI requirements.
Fan consultation: meaningful, regular and evidenced
The fan consultation chapter requires clubs to consult meaningfully and regularly with fans on relevant matters. Relevant matters include the club’s strategic direction and objectives, business priorities, operational and matchday issues including ticket pricing, club heritage and additional fan engagement. Heritage includes home ground, crest, home shirt colours and team name.
Clubs must consult either elected fan representatives or persons who appear to the IFR to represent fan views. Elected processes should be democratic, independent, fair and proportionate. Appointed groups should reflect a broad range of fan perspectives, be selected through a transparent and open appointment process, and be willing and able to engage.
The IFR’s Principles for Fan Consultation require consultation to be collaborative, two-way, open and integrated. The annual fan consultation report must explain and evidence how the club complied with those principles during the previous year and how it intends to comply in the upcoming year.
The report must be submitted between 1 June and 15 August and published online as soon as reasonably practicable after submission. The IFR may request supplementary evidence and supervisors may engage directly with fan representatives.
DLCs are the IFR’s targeted intervention tool
Discretionary Licence Conditions are a key part of the IFR’s supervisory approach. They can be applied to provisional and full licences where compliance would help the club meet or continue to meet one or more Threshold Requirements, or advance the IFR’s objective of promoting systemic financial resilience.
There are four types: financial resources DLCs, non-financial resources DLCs, fan engagement DLCs and systemic resilience DLCs. Financial resources DLCs may relate to debt management, liquidity requirements, restrictions on overall expenditure, or restrictions on accepting or receiving funding the IFR reasonably suspects is connected to serious criminal conduct. Non-financial resources DLCs may relate to internal controls, risk management or financial reporting. Fan engagement DLCs seek to ensure adequate and effective consultation. Systemic resilience DLCs may relate to debt management, liquidity requirements or restrictions on overall expenditure.
The IFR will take a proportionate and risk-based approach and will engage with clubs before applying a DLC where possible. The process generally includes notification, representations, decision and supervision. But once imposed, a DLC is a licence condition. Failure to comply may result in enforcement action.
The heritage duty sits alongside the licensing regime
Chapter 8 addresses Section 49 of the Act, which requires regulated clubs not to make material changes to a crest, emblem or predominant home shirt colours unless reasonable steps have been taken to establish that the changes are supported by a majority of fans in England and Wales. Clubs also must not change the name of a relevant team unless the change has been approved by the FA.
The IFR interprets reasonable steps by reference to the fan consultation framework. Clubs should adopt an approach that is collaborative, two-way, open and integrated, and should meaningfully engage with fans who reflect the diversity of the club’s fanbase. Evidence may include surveys, polls, questionnaires, minutes of meetings with fan representatives and supporter groups, and focus group minutes.
This is not simply a brand decision. For regulated clubs, heritage changes now sit inside a statutory framework linked to consultation and evidence.
How Lagom Sports Compliance can support your club
Lagom Sports Compliance provides specialist IFR licensing support for English football clubs.
Every engagement starts with an initial conversation. We assess your timeline, internal capability, ownership structure and current position against the IFR requirements. We then tell you honestly which level of support is appropriate. No commitment. No generic templates. No pretending that a licensing submission can be assembled at the last minute.
The IFR licensing regime is now a live operating requirement. The question is not whether your club needs to comply. It is whether your board has the evidence, documentation and internal accountability to show compliance when the IFR asks.
Answering your questions about ongoing IFR licence compliance
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The IFR Licensing Guidance explains how clubs should comply with their ongoing licensing obligations. It covers financial regulation, non-financial resources, corporate governance, fan consultation and engagement, annual declarations, Discretionary Licence Conditions and certain heritage duties.
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The four Mandatory Licence Conditions are financial plans, corporate governance statements, fan consultation and annual declarations. They apply to all clubs from the date they receive a provisional licence and continue on a full licence.
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The three Threshold Requirements are appropriate financial resources, appropriate non-financial resources and fan engagement. Clubs must meet them before the IFR can grant a full licence and must continue to meet them once on a full licence.
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For most clubs licensed ahead of the 2027/28 season, the first financial plan is due in May 2028, within the 17 May to 31 May reporting window. The IFR may require earlier or more frequent reporting where there are concerns.
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It means the club has financial resources of an appropriate amount and quality for its activities and risks. The IFR focuses on cash inflows and outflows, funding reliability, liquidity, solvency and the club’s ability to manage adverse scenarios, not simply accounting presentation.
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Financial plans must include stress tests for a 10% reduction in annual income, relegation and, where the club relies on external funding to cover deficits, removal of the club’s main source of external funding. Clubs that do not rely on external funding to cover deficits should discuss this with their supervisor and document why that scenario is not required. Clubs must also provide stress mitigation plans.
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It is the statement in which a club explains how it applies the IFR Football Club Corporate Governance Code and what action it is taking to improve equality, diversity and inclusion. The first statement is due by 31 October 2027 and must be published online.
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It is the annual report explaining and evidencing how the club has consulted fan representatives on relevant matters and how it intends to consult in the coming year. It must be submitted between 1 June and 15 August and published online.
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A DLC is an additional licence condition the IFR may attach where it would help the club meet Threshold Requirements or advance systemic financial resilience. DLCs may relate to financial resources, non-financial resources, fan engagement or systemic resilience.
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Yes, but the IFR says revocation or suspension would occur only in specific circumstances and that it would usually seek to address concerns through supervisory tools, such as DLCs, before revocation or suspension. If a licence is revoked or suspended mid-season, it takes effect from the end of that season.