What is an IFR skilled person and how does a football club avoid ever needing one?
Schedule 9 of the Football Governance Act 2025 gives the Independent Football Regulator the power to require a club to appoint a specialist, nominated by the IFR itself, to help bring an unresolved compliance failure to an end. It is easy to mistake this for a version of the advisory support clubs already engage voluntarily. It is not. The distinction between choosing your own adviser and having one nominated for you by your regulator is the entire point of this article and the most useful thing any club can take from it is exactly what it looks like to never need one.
What triggers a skilled person appointment
Schedule 9, paragraph 5 of the Act sets out the precise circumstances in which the IFR can require a club to appoint a skilled person. Two conditions must both be met. First, the IFR must have determined -- whether as a result of a formal investigation or otherwise -- that a club has, without reasonable excuse, committed a relevant infringement. Second, and critically, that infringement must be continuing. This is not a power the IFR can reach for at the first sign of trouble. It is a remedial tool specifically designed for situations where a determination has already been made and the underlying problem has not been resolved.
It sits within a wider set of Schedule 9 remedies available to the IFR once it has determined that a relevant infringement has occurred. The skilled person power is one option among several: the IFR can also impose financial penalties -- capped, for a club, at 10% of total revenue, calculated as a fixed amount, a daily rate, or a combination of both -- apply to the Tribunal for an injunction to bring a continuing relevant infringement to an end, and, in the most serious cases, suspend or revoke a club's operating licence altogether. The skilled person power is distinctive within that set because it is not primarily punitive. It is designed to actually fix the underlying problem, with the IFR retaining direct influence over who does the fixing.
The skilled person power is not primarily punitive. It is designed to actually fix the problem -- with the regulator, not the club, deciding who does the fixing.
What a skilled person actually does, and what the club must give them
Once triggered, the mechanism works as follows. The IFR may require the club to appoint a person nominated by the IFR -- described in the Act as a skilled person -- to assist the club in bringing the continuing relevant infringement to an end. The IFR's power to nominate is not unconstrained: it may only put forward a person it is satisfied has the skills necessary to assist the club in resolving the specific infringement, and who has no conflict of interest that would compromise their independence in doing so.
Once appointed, the club is under a specific and demanding duty. It must co-operate with the skilled person, and it must give the skilled person such reasonable assistance as the skilled person requests -- which the Act specifies expressly includes access to business premises, equipment, services, information and individuals, in connection with bringing the infringement to an end. This is a broad and intrusive access right, closer in character to the assistance obligations owed to an expert reporter or a formal IFR investigation than to a typical professional engagement.
Failure to cooperate is not a passive risk. Obstructing a skilled person appointed under Schedule 9 is itself listed in the Act as a relevant infringement in its own right, alongside obstructing a court-appointed officer, a trustee, or an expert reporter. A club that resists or frustrates the skilled person it has been required to appoint is not merely being unhelpful. It is committing a fresh, independent breach of the Act, layered on top of the original infringement that made the appointment necessary in the first place.
Who bears the cost
The Act is clear that the club is required to appoint the skilled person nominated by the IFR, but Schedule 9 paragraph 5 does not itself set out a detailed cost-allocation provision in the supplied text. In practice, a skilled person appointment should still be treated as a serious commercial exposure: it will consume management time, require access to premises, systems, information and individuals, and may sit alongside separate financial penalties or other sanctions for the underlying infringement.
Why a skilled person is not the same as your own adviser
This is the distinction that matters most, and it is worth setting out plainly, because it is easy for a club to hear "specialist appointed to help resolve a compliance issue" and assume this is broadly equivalent to engaging their own external advisers. It is not, on three specific and consequential points.
Who chooses. A club's own adviser is selected by the club, on the club's own criteria, with the freedom to change adviser if the relationship is not working. A skilled person is nominated by the IFR. The club does not choose who is appointed, and the Act gives the club no equivalent freedom to reject the nomination and select someone else, provided the IFR is satisfied the nominee has the necessary skills and no conflict of interest.
What the appointment signals. Engaging your own adviser voluntarily is, if anything, a positive governance signal -- evidence that the club is taking a matter seriously and investing in getting it right. A skilled person appointment is the opposite signal. It exists only because the IFR has already determined that a relevant infringement occurred, without reasonable excuse, and that the infringement is continuing. The appointment itself is not a preventative measure. It is a clear regulatory signal that a prior compliance failure was serious enough, and unresolved for long enough, to warrant direct regulatory intervention into how the club puts it right.
Whose interests the appointment serves. A club's own adviser reports to the club and is bound by the ordinary professional and confidentiality obligations of that relationship. A skilled person is nominated by, and in practical terms accountable to, the regulator that appointed them -- their function under the Act is defined as assisting the club to bring the infringement to an end, which is a different mandate to a conventional advisory relationship built around the club's own instructions and priorities.
The commercial and reputational reality of an appointment
Beyond the operational burden, a skilled person appointment carries consequences that extend well past the specific infringement it is meant to resolve. The appointment sits within a regulatory framework that, consistent with the IFR's approach to censure statements and other public sanctions, is not designed for quiet resolution. A club under a skilled person appointment is, in effect, subject to direct regulatory intervention in the specific area of its business to which the continuing infringement relates -- financial reporting, governance arrangements, fan consultation processes, or whatever the underlying failure concerned.
That visibility has practical knock-on effects. Banking relationships, commercial partners, and prospective investors are all, in varying degrees, sensitive to signs of unresolved regulatory difficulty at a club. A skilled person appointment is precisely that kind of signal, and it arrives at a point in the process -- after a determination has already been made and the infringement is confirmed as continuing -- where the club has limited ability to control the narrative around it.
How a club avoids ever needing one
The clearest way to think about the skilled person power is as the mechanism the Act reaches for specifically where earlier, less intrusive stages of the compliance relationship have not worked. That framing points directly to the practical answer to the question this article is built around.
Resolve infringements before they become continuing ones. The trigger for a skilled person is not simply that an infringement occurred -- it is that the infringement is continuing at the point the IFR considers its remedial options. A club that identifies a compliance gap and closes it promptly, even after the fact, is in a fundamentally different position to one that allows the same gap to persist. The window between an infringement occurring and it becoming a continuing, unresolved one is the window in which a club retains control over how the matter gets fixed, and by whom.
Treat governance capability as infrastructure, not a response to a specific problem. Clubs that build genuine, standing governance and compliance capability -- clear ownership of IFR obligations at board level, documented processes for the mandatory licence conditions, active monitoring of material changes affecting owners and officers -- are structurally less likely to accumulate the kind of unresolved, continuing infringement that triggers this power in the first place. This is the direct, practical version of the point this whole series of articles has been making: the enforcement mechanisms the Act provides are real, specific, and more consequential than generic compliance commentary suggests, but they are also, in every case, avoidable through the same underlying discipline.
Engage advisers of your own choosing while you still have the choice. The entire distinction this article has drawn, between a specialist you choose and one nominated for you, only has commercial value if a club acts on it before the choice is taken away. A club that engages its own governance and compliance support proactively, on its own terms, is exercising precisely the freedom that disappears the moment a skilled person is imposed.
For the detail of the IFR's other enforcement and investigative powers -- including the expert reporter mechanism that can precede a determination of this kind, and the internal review and appeals process available if a club disagrees with an IFR decision -- see Lagom's companion articles on section 66 and on the IFR's licence refusal and appeals process.
The best relationship with a skilled person is never having one appointed at all.
Understanding whether a specific compliance gap is drifting toward becoming a continuing infringement, and getting the right support in place before that happens, is often a focused and time-sensitive question 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 a specific governance or compliance gap before it escalates, or a fixed number of hours each month at a discounted rate for clubs that want ongoing access to specialist input on their own terms. If your club wants to close a compliance gap proactively, on its own timetable and with advisers of its own choosing, get in touch to talk through what that looks like.
Frequently asked questions: the IFR's skilled person power
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A skilled person is an individual nominated by the Independent Football Regulator, under Schedule 9 paragraph 5 of the Football Governance Act 2025, whom a club can be required to appoint to help bring a continuing, unresolved compliance failure to an end. The IFR may require this appointment where it has determined that a club has, without reasonable excuse, committed a relevant infringement, and that infringement is continuing. The IFR may only nominate someone it is satisfied has the necessary skills and no conflict of interest.
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Schedule 9 paragraph 5 requires the club to appoint the person nominated by the IFR, but the supplied Act text does not expressly set out a standalone cost-allocation rule for skilled persons. The safer position is to treat the appointment as a serious commercial and operational exposure, rather than stating as a statutory certainty that the club bears all costs.
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No. The Act gives the IFR, not the club, the power to nominate the skilled person, subject only to the IFR being satisfied that the nominee has the necessary skills and no conflict of interest. This is the central distinction between a skilled person and a club's own voluntarily engaged adviser: the club does not choose who is appointed and has no equivalent right to reject the nomination in favour of an alternative of its own choosing.
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Under Schedule 9 paragraph 5, a club must co-operate with the skilled person and give them such reasonable assistance as they request, which the Act specifies expressly includes access to business premises, equipment, services, information and individuals, in connection with bringing the relevant infringement to an end. This is a broad and intrusive access requirement, comparable to the assistance obligations owed to an IFR expert reporter or formal investigation.
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Obstructing a skilled person appointed under Schedule 9 of the Act is itself a relevant infringement in its own right, separate from the original infringement that led to the appointment. This sits alongside the equivalent obligations not to obstruct a court-appointed officer, a trustee, or an expert reporter appointed under section 66. A club that fails to cooperate is committing a fresh, independent breach of the Act, with potential financial penalty exposure, subject to the statutory caps in Schedule 9.
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Because the power is triggered specifically where a relevant infringement is continuing and unresolved, the most direct way to avoid it is to identify and close compliance gaps before they reach that point, rather than allowing a determined infringement to persist. Clubs that build genuine, standing governance and compliance capability -- clear board-level ownership of IFR obligations, documented processes for the mandatory licence conditions, and proactive engagement with their own chosen advisers -- are structurally less likely to accumulate the kind of unresolved infringement that leads the IFR to nominate a skilled person in the first place.