The IFR ODSE regime: who needs approval, what the regulator assesses, and what clubs must do now
The Independent Football Regulator's Owners, Directors and Senior Executives regime came into force on 5 May 2026. It is not a future obligation. It is not a consultation. Every regulated club in the top five tiers of English men's professional football must comply with it now and most clubs are only beginning to understand what that compliance actually requires.
What the ODSE regime actually is
Professional football in England has operated for decades without any formal statutory test for who can own or run a club. Extraordinary wealth, opaque structures and catastrophic management failures have been a recurring feature of the game -- from the Bury collapse in 2019 to the Wigan Athletic administration in 2020 and the near-passage of the European Super League in 2021. The Football Governance Act 2025, which received Royal Assent on 21 July 2025, was the legislative response. The Owners, Directors and Senior Executives regime is its sharpest tool.
To learn more about The Football Governance Act and IFR licensing, you may find the following articles useful:
The ODSE regime gives the Independent Football Regulator the power to assess and determine the suitability of prospective owners and senior executives of regulated clubs -- and, under certain circumstances, incumbent ones. That power came into full effect on 5 May 2026. Since that date, the law is unambiguous: no person may become an owner of a regulated club, and no individual may take up a Senior Management Function at a regulated club, unless the IFR has first determined them to be suitable.
No person may become an owner or Senior Manager of a regulated club unless the IFR has determined them to be suitable. There is no grace period, no self-certification and no informal workaround.
This is a mandatory, suspensory regime. The word suspensory matters. A prospective owner cannot complete an acquisition while their application is pending. A prospective senior manager cannot take up their post. The deal, or the appointment, waits for the IFR's determination. Clubs and prospective owners that structure transactions without building IFR engagement into the timeline are not cutting corners. They are breaking the law.
Additionally, the IFR maintains a public register of determinations made, which it aims to update on a weekly basis. You can find the IFR’s current list of ODSE determinations here.
Who is in scope: owners
The definition of an owner under the Football Governance Act 2025 is deliberately broad and deliberately substance-over-form. It is not about who holds shares in the name-plate company. It is about who, in practice, exerts control or influence over the regulated club. Under Schedule 1 of the Act, an individual qualifies as an owner if they meet any one of five conditions:
They have the right to exercise, or actually exercise, significant influence or control over the club's activities.
They hold, directly or indirectly, more than 25% of the shares in the club.
They hold, directly or indirectly, more than 25% of the voting rights in the club.
They hold the right, directly or indirectly, to appoint or remove a director or Senior Manager of the club.
They exercise significant influence or control over a trust, partnership or other non-legal entity that itself meets one or more of conditions one to four.
Two things about this definition deserve particular attention. First, ownership conditions can be met even where shares or control rights are held through corporate structures, nominees or offshore vehicles. The test looks through the structure to the individual. A prospective investor sitting behind a Cayman Islands holding company, a Luxembourg intermediate entity and a domestic acquisition vehicle is still an owner for IFR purposes if they meet any of the five conditions. The structure does not neutralise the obligation. It may, however, materially extend the time required for the IFR to validate the application.
Second, a club may have more than one owner. Two individuals each holding 26% of the shares are both owners. A trust beneficiary who exercises significant influence alongside a majority shareholder may also be an owner. Clubs must identify all individuals who meet the conditions, not simply the largest single shareholder.
The concept of significant influence or control deserves its own analysis. The Secretary of State for Culture, Media and Sport published statutory guidance on this in December 2025. The IFR is required to have regard to that guidance and clubs and prospective investors should read it carefully before making any assumption about whether the threshold is met.
Who is in scope: the six Senior Management Functions
The IFR has used its rulemaking powers under the Act to define six Senior Management Functions. Anyone performing one of these roles on a permanent basis at a regulated club is in scope of the ODSE regime and requires the IFR's prior approval.
| Function | Code | What it covers |
|---|---|---|
| Chair | SMF1 | Responsibility for chairing the board and overseeing its performance. |
| Chief Executive | SMF2 | The most senior executive responsible for conducting and managing the whole of the club's business. |
| Chief Finance | SMF3 | Management of financial resources, financial planning and financial reporting, including direct board reporting. |
| Chief Operations | SMF4 | Overall responsibility for managing all, or substantially all, of the club's internal operations. |
| Director | SMF5 | Acting as a registered director under the Companies Act 2006, or as a shadow director. |
| Other Key Decision Maker | SMF6 | Significant influence over the management or conduct of one or more aspects of the club's regulated activities -- the catch-all for influential individuals outside SMF1 to SMF5. |
The IFR has been deliberate in grounding each function in responsibilities rather than job titles. A Finance Director performing the duties described under SMF3 is in scope, regardless of whether their formal title uses the word Chief. A Commercial Director whose role does not include board membership is not automatically in scope of SMF5 simply because their title includes the word Director. What matters is what the role actually involves.
The catch-all: SMF6 and the Other Key Decision Maker function
SMF6 is the provision clubs most commonly underestimate. Its purpose is to prevent highly influential individuals from remaining outside the ODSE regime by holding a title that falls between the explicitly defined functions. The IFR's ODSE Guidance (paragraph 2.15) describes the individuals SMF6 is intended to capture as those who have a continued and high degree of decision making authority or influence over the day-to-day management and conduct of a club's regulated activities, and who perform a role not covered by SMF1 to SMF5.
In practice, this brings two categories of individual into particular focus. The first is the executive Sporting Director -- specifically, one who holds decision-making authority over player transfers or contracts, not merely one whose responsibilities are confined to sporting and on-pitch matters. A Sporting Director who can authorise transfers and approve contracts sits within SMF6. One who cannot is likely outside it. The second is any individual, regardless of formal title, who holds executive authority over significant financial decisions but does not sit on the club's board.
Simply because a role is not included in the IFR's illustrative examples does not mean it is not in scope. The determining factor is whether the individual has a continued and high degree of decision-making authority over the club's regulated activities.
Shadow directors also fall within scope. The IFR expects clubs to identify when an individual is effectively directing the board without formal appointment and to treat that person as falling within SMF5. Where the IFR identifies an individual performing a shadow director role who is not registered under the ODSE regime, it will require an application to be submitted.
The application process: notifications and approvals
The ODSE regime operates in two sequential stages. The first is notification. The second is application. Both carry legal obligations, and confusing them -- or conflating them, is a frequent source of procedural difficulty.
Notifications: the early warning
Clubs and individuals must notify the IFR when there is a reasonable prospect of someone becoming an owner or Senior Manager. This is a low threshold by design. For Senior Managers, the IFR has indicated that it is content to receive a notification when the club has identified a single preferred candidate -- meaning a notification can, in practice, be submitted simultaneously with a formal application. For ownership changes, the IFR expects notification when a bid is sufficiently advanced that it is likely to result in a change of ownership. Earlier notification is better. The IFR explicitly recommends it.
The IFR will not conduct a suitability assessment at the notification stage. It will record the notification and await a complete application. Crucially, it will not provide indicative views on whether an application is likely to succeed. Clubs and prospective owners wishing to form that view must self-assess.
Applications: the formal process
All applications must use the IFR's prescribed application forms. There are separate forms for prospective owners and for Senior Management Functions. Applications submitted in any other format will not be accepted, and incomplete applications will delay the determination -- which, under the Act's mandatory timelines, has real commercial consequences.
For owner applications, the Act requires specific information to be included as a minimum: the proposed operation of the club, the estimated costs of that operation, how those costs will be funded, and the source of that funding. The IFR's application form sets out the full requirements. Prospective owners and regulated clubs should treat the form as the starting point for structuring their due diligence package, not an afterthought once terms are agreed.
For Senior Management Function applications, the IFR requires information relating to competence -- qualifications, experience, training and the club's own hiring process -- that is not required from prospective owners. Conversely, Senior Manager applications do not require information on financial resources or how the club will be funded.
Once a complete application has been received and acknowledged by the IFR, the clock starts. The IFR has 90 days to make a determination, extendable to 150 days in exceptional circumstances. The IFR has indicated it expects extensions to be rare. For ownership transactions, that 90-day window needs to be built into deal timelines as a hard constraint, not a hopeful estimate.
What the IFR assesses: the suitability tests
The suitability assessment is not a background check. It is a structured regulatory evaluation conducted against legally defined criteria. The criteria differ between owners and Senior Managers, but share a common core.
Honesty and integrity
This criterion applies to all owners and all Senior Managers. The IFR must have regard to criminal convictions and proceedings anywhere in the world; conduct outside England and Wales that would constitute a serious offence if committed here; court or tribunal proceedings of any kind; regulatory or disciplinary action in any jurisdiction; whether the individual is subject to sanctions or prohibited from entering the UK; enforcement action by any sporting competition organiser; and whether the individual has misled or failed to cooperate with the IFR, a competition organiser or any other regulatory body.
The IFR will not automatically disqualify an individual on any of these grounds. It will assess each application on a case-by-case basis, taking into account the nature and seriousness of the matter, its relevance to the role, the time that has elapsed, any rehabilitation and any representations made by the individual. What it will not do is ignore disclosable matters. All criminal convictions must be disclosed without exception. All court or tribunal proceedings must be disclosed. All regulatory or disciplinary action must be disclosed. A DBS check is required for every applicant.
Financial soundness
Financial soundness is assessed for both owners and Senior Managers, but it is not the same as having sufficient financial resources to operate the club. The IFR examines personal financial history: bankruptcy, estate sequestration, Individual Voluntary Arrangements, debt management schemes and equivalent procedures in any jurisdiction. It also examines the financial track record of any body in which the individual has held a position of responsibility -- including any football club, company or partnership they have directed or controlled that has experienced financial distress, entered administration or been liquidated.
The IFR has indicated it will give additional scrutiny to the financial history of any football club or sporting entity an applicant has previously controlled. Financial distress at a football club under an applicant's watch is not a bar to approval, but it will be examined carefully.
Source of wealth: the provision most relevant to ownership transactions
For prospective owners only, the IFR must also consider whether there are grounds to suspect that the applicant has any source of wealth connected to serious criminal conduct -- conduct that amounts to, or would amount to, an offence specified in Part 1 of Schedule 1 to the Serious Crime Act 2007. If the IFR has grounds to suspect such a connection, it must refuse the application. The evidential threshold for refusal is low. It is suspicion, not proof.
The practical implications are considerable. Prospective owners must explain and evidence their source of wealth in their application. The IFR may request information from banks, advisers and third parties. It may engage law enforcement agencies. The club itself is expected to have conducted its own due diligence on the prospective owner's funds before submitting the application. Both the club and the applicant must sign a declaration confirming that the source of funds, to the best of their knowledge, is not connected to serious criminal conduct.
The source-of-wealth provision shares its conceptual DNA with AML regulation. Clubs and prospective owners who have invested in robust beneficial ownership and source-of-wealth documentation for AML purposes will find that material directly applicable to the IFR's assessment. Those who have not will face both simultaneously.
Competence: for Senior Managers only
Senior Management Function applicants are also assessed on competence -- their qualifications, experience and training relevant to the specific role they will perform. The IFR is explicit that it will not assess competence in terms of football knowledge, on-pitch performance or transfer market acumen. Competence is evaluated in the context of the IFR's statutory objectives: running a club in a financially sustainable way, safeguarding its heritage and engaging appropriately with fans.
The IFR will take into account the scale and complexity of the club's operations and its current circumstances. A Chief Finance Officer appointment at a Premier League club with EUR 300 million in annual revenue will be assessed differently from the same role at a National League club. Football experience is not a prerequisite, but relevant experience in comparable organisations will be weighted.
Incumbent owners and Senior Managers: the ongoing obligation
The ODSE regime does not apply only to prospective owners and new appointments. The IFR has powers to assess incumbent owners and Senior Managers in certain circumstances -- specifically, where it is in possession of information that gives it grounds for concern about their suitability, or grounds to suspect that an owner's source of wealth is connected to serious criminal conduct.
This is a discretionary power, not a mandatory one. The IFR is not required to conduct periodic reviews of all incumbents. It will exercise the power on a case-by-case basis, based on the strength of its concerns, the evidence available and the extent of the threat to its statutory objectives. But the power exists, and its existence changes the calculus for incumbent owners and Senior Managers in an important way: suitability is not a one-time determination that expires. A finding of suitability at the point of approval holds until the person ceases to be an owner or Senior Manager, or until the IFR makes a subsequent determination that they are no longer suitable.
Clubs, owners and Senior Managers are required to notify the IFR as soon as reasonably practicable where there has been, or may have been, a material change in circumstances relevant to suitability. The IFR Guidance gives illustrative examples: criminal proceedings, regulatory action, bankruptcy and organisational insolvency. These are not exhaustive. Any matter touching on honesty and integrity, financial soundness or -- for Senior Managers -- competence may require notification.
The penalty architecture: what non-compliance actually costs
The Football Governance Act 2025 establishes a layered sanctions regime under Schedule 9 that applies to all relevant infringements, including failures under the ODSE regime. Clubs and individuals should understand what is on the table before concluding that a procedural shortcut is worth the risk.
The IFR may publish a censure statement naming the club or individual and describing the infringement. It may appoint a skilled person -- nominated by the IFR, paid for by the club -- to assist in ending a continuing infringement. And it may impose a financial penalty of up to 10% of total club revenue, calculated as a fixed amount or a daily rate for continuing breaches. That ceiling applies separately for information-related infringements.
For a Premier League club generating several hundred million pounds in annual revenue, 10% is a nine-figure exposure. For a League Two club, it is existentially significant. The IFR has discretion to impose less -- but clubs should plan on the assumption that material non-compliance will attract material consequences.
Personal liability is explicitly built into the Act's architecture. A senior manager of a club that commits a relevant infringement without reasonable excuse may themselves face financial penalties. This is not a theoretical provision. It is the mechanism that makes ODSE compliance a board-level issue, not a legal or HR administration task.
The most operationally consequential consequence of non-compliance may not be the regulatory fine. Banks increasingly treat professional football as a higher-risk client segment, applying enhanced due diligence and in some cases de-risking club accounts entirely. A club that cannot demonstrate clean, approved ownership and a functioning governance framework presents a materially worse banking risk profile than one that can. The loss of banking relationships, and the operational paralysis that follows, is a practical consequence of compliance failure that sits entirely outside the IFR's enforcement toolkit but can arrive faster than any regulatory sanction.
The ODSE regime and the operating licence: the accountability loop
The ODSE regime does not operate in isolation. It connects directly to the IFR's mandatory operating licence conditions, which every regulated club must satisfy to compete from the 2027/28 season. Understanding that connection matters because it transforms ODSE compliance from a one-time approval exercise into an ongoing governance obligation with a fixed annual accountability mechanism.
Under Schedule 5 of the Act, every operating licence must include an annual declaration condition. Each year, clubs must certify to the IFR either that all notifiable matters -- including material changes in circumstances affecting the suitability of an owner or Senior Manager -- have been reported during the preceding twelve months, or that there were no such matters. This creates a formal accountability loop. The material change notification duty under the ODSE regime feeds directly into the annual declaration. A club that fails to notify the IFR of a relevant change in an owner's or Senior Manager's circumstances, and then signs an annual declaration confirming full compliance, has compounded a substantive ODSE failure with a false certification.
The financial plans condition adds a further layer. Clubs must submit and annually update a financial plan that includes information on how the club is or will be funded and the source of that funding. Where ownership structures change, or where new investors come on board, the financial plan requires updating as soon as reasonably practicable. That update creates documentary evidence of the funding chain that sits alongside, and is consistent with, the source-of-wealth information the IFR reviewed in the ownership application. Inconsistencies between the two are the kind of discrepancy a regulator notices.
The convergence with EU AML 2024/1624
English clubs now face two significant and partially overlapping regulatory frameworks simultaneously. The IFR operates domestically under the Football Governance Act 2025, covering ownership integrity, senior management fitness, financial soundness and governance. EU Regulation 2024/1624, the Anti-Money Laundering Regulation, brings professional football clubs and agents inside the formal AML perimeter from 10 July 2029, requiring customer due diligence, sanctions screening, source-of-wealth analysis and documented governance frameworks for investor transactions, sponsor deals, agent payments and player transfers.
The overlap is not incidental. Both regimes are, at their core, addressing the same risk: the use of football as a vehicle for financial crime, regulatory arbitrage and the placement of illicit wealth into legitimate structures. The IFR's source-of-wealth test for prospective owners under section 28(4)(b) of the Act and the AMLR's source-of-wealth and beneficial ownership due diligence obligations for investor transactions address the same underlying exposure from different regulatory angles. A club that builds rigorous beneficial ownership documentation and source-of-wealth verification for the IFR process will find that material directly applicable to its AMLR obligations. A club that does neither will face both sets of requirements simultaneously, with compounding gaps and no head start on either.
The practical lesson applies beyond financial crime compliance. A defensible ownership file, a documented financial governance framework, structured fan consultation records and a trained senior management team approved under the ODSE regime serve the IFR, the AMLR, UEFA licensing, and the banking relationships that underpin a club's ability to function. Compliance investment made in one area is not siloed. It compounds.
Understanding where your club stands
The ODSE regime is not a compliance project to be scheduled for a future quarter.
It is in force. Every regulated club must understand, right now, whether its incumbent owners and Senior Managers have been assessed and approved, whether any pending appointments or ownership changes require IFR notification and application, whether its SMF6 population has been correctly identified, and whether it has the processes in place to manage material change notifications on an ongoing basis, and to translate those notifications into accurate annual declarations.
Lagom Sports Compliance is a specialist compliance advisory firm built for professional football. The firm advises clubs, prospective owners and their advisers on ODSE regime readiness, source-of-wealth documentation, senior management fitness assessments, operating licence compliance and the intersection of IFR obligations with EU AML 2024/1624 requirements.
For clubs and advisers requiring structured support on ownership transactions, senior management appointments or ongoing ODSE compliance, contact Lagom Sports Compliance directly today.
Frequently asked questions: the IFR ODSE regime
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The Owners, Directors and Senior Executives regime is the framework established by the Independent Football Regulator under the Football Governance Act 2025 to assess and determine the suitability of owners and senior managers of regulated clubs. It came into full effect on 5 May 2026. It requires that no person becomes an owner of a regulated club, and no individual takes up a Senior Management Function, without prior approval from the IFR. Failure to comply constitutes a relevant infringement under the Act and may result in enforcement action.
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The regime applies to all regulated clubs, those operating a team entered into a specified competition under the Football Governance Act 2025. Currently, this covers all clubs in the Premier League, Championship, League One, League Two and Step 1 of the National League. That is 116 clubs in total. Clubs in the National League North and National League South with a reasonable prospect of promotion to the National League are also expected to engage with the regime in advance of promotion.
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An owner is any individual who meets one or more of five ownership conditions set out in Schedule 1 of the Football Governance Act 2025. These cover holding more than 25% of shares or voting rights, holding the right to appoint or remove a director or Senior Manager, and exercising significant influence or control over the club's activities. The definition is substance-over-form: ownership conditions can be met even where interests are held through corporate structures, offshore vehicles or nominees. A club may have more than one owner.
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The IFR has defined six Senior Management Functions (SMFs): Chair (SMF1), Chief Executive (SMF2), Chief Finance (SMF3), Chief Operations (SMF4), Director (SMF5), and Other Key Decision Maker (SMF6). Anyone performing one of these roles on a permanent basis at a regulated club requires IFR approval before taking up the position. Roles are assessed by their actual responsibilities rather than job title. Shadow directors fall within SMF5 regardless of their formal title.
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SMF6 is the catch-all function designed to bring highly influential individuals into the ODSE regime even where their role does not correspond to one of the other five named functions. It applies to individuals with a continued and high degree of decision-making authority or influence over the day-to-day management and conduct of the club's regulated activities. A Sporting Director with executive authority over player transfers and contracts is a commonly cited example. First-team managers, medical staff and scouting personnel are generally not in scope, as they typically lack executive financial authority.
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For prospective individual owners, the IFR assesses three things: honesty and integrity (including criminal history, regulatory action, sanctions designations and conduct in any jurisdiction), financial soundness (including personal insolvency history and the financial track record of any body the individual has controlled), and whether the applicant has any source of wealth connected to serious criminal conduct. If the IFR has grounds to suspect a source-of-wealth connection to serious criminal conduct, it must refuse the application. Registered societies seeking ownership are assessed only on sufficient financial resources.
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Once the IFR has confirmed it has received a complete application, it has 90 days to make a determination. This period can be extended to 150 days in exceptional circumstances, including complex ownership structures, multi-jurisdictional verification requirements, material changes in the applicant's circumstances during the assessment period, or incomplete cooperation from the applicant. Clubs and prospective owners should build the full 90-day window into deal and appointment timelines as a hard constraint.
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Becoming an owner or Senior Manager of a regulated club without prior IFR approval and a positive suitability determination constitutes a relevant infringement under the Football Governance Act 2025. The IFR may require the individual to submit a retrospective application and has the power to determine that person to be unsuitable. If found unsuitable, the IFR must issue removal directions and may disqualify the individual from being an owner or Senior Manager of any regulated club. Financial penalties of up to 10% of total club revenue may also apply.
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The Football Governance Act 2025 establishes a layered sanctions regime under Schedule 9. For relevant infringements, including becoming an owner or Senior Manager without IFR approval, failing to notify material changes in circumstances, and breaching licence conditions, the IFR may publish a censure statement naming the club or individual, appoint a skilled person at the club's cost to assist remediation, and impose a financial penalty of up to 10% of total club revenue. For information-related infringements, a separate 10% cap applies. Senior managers who cause or permit a club to commit a relevant infringement without reasonable excuse may themselves face personal financial penalties. Separately, clubs that cannot demonstrate clean, approved ownership and a functioning governance framework face materially worse banking relationships, including the risk of enhanced due diligence or account de-risking by their banking partners.
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The ODSE regime feeds directly into the mandatory operating licence conditions every regulated club must satisfy under Schedule 5 of the Act. The annual declaration condition requires clubs to certify each year either that all notifiable matters, including material changes affecting the suitability of an owner or Senior Manager, have been reported, or that there were no such matters. A club that fails to notify the IFR of a relevant change and then signs an annual declaration confirming full compliance has compounded a substantive ODSE failure with a false certification. The financial plans condition similarly requires clubs to update their documented funding information whenever ownership structures change, creating consistency requirements between the licence framework and the source-of-wealth information reviewed during the owner approval process.
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Yes, significantly. The IFR's source-of-wealth assessment for prospective owners and the EU Anti-Money Laundering Regulation's source-of-wealth and beneficial ownership due diligence requirements for investor transactions address the same underlying risk from different regulatory angles. A club that builds robust source-of-wealth documentation and beneficial ownership verification for IFR purposes will find that work directly applicable to its AMLR obligations when those come into force for football on 10 July 2029. Clubs subject to both frameworks should build integrated compliance processes rather than treating each obligation in isolation. Compliance investment in ownership documentation and governance serves the IFR, the AMLR, UEFA licensing and banking relationships simultaneously, it is not a cost that needs to be incurred twice.