Can one person hold multiple SMFs at a football club? Delegation, shared responsibility and temporary cover explained
A smaller club’s Chair also runs finance. A Chief Executive goes on sudden medical leave before a transfer deadline. A General Counsel delegates routine contract review. These familiar situations raise related but distinct questions under the IFR’s ODSE regime: can one individual hold more than one Senior Management Function (SMF); when may someone cover an absent SMF holder; can responsibility be shared; and what does delegation change? The final rules now answer some of those questions expressly, while others depend on the wording of the particular SMF and the club’s actual governance arrangements.
Temporary cover: the final rule now in force
The IFR’s amended ODSE Rules and Guidance took effect on 5 May 2026. They create a temporary-appointment route for a reasonably unforeseen absence from an SMF. The rules distinguish between cover by an existing Senior Manager at the club and cover by an individual who is not already an existing Senior Manager there.
That distinction matters because the two routes have different forms, safeguards and start conditions. It is also the clearest example of one person carrying more than one SMF’s responsibilities at the same time.
An existing Senior Manager can cover a reasonably unforeseen absence without the 12-week cap or the special decision-making limits, but the club must notify the IFR and ensure that the person has the necessary qualifications. A non-existing Senior Manager needs the IFR's written no-objection before starting and is normally subject to the 12-week and decision-making safeguards.
Why the distinction matters in practice
The existing-Senior-Manager route is not based on an assumption that the IFR has already assessed that person for every possible function: incumbent Senior Managers may not have received a prospective approval, and competence is role-specific. Instead, the route uses someone who is already within the club’s senior-management structure. No baseline fitness checks or application are required, but the club must still ensure that the individual has the qualifications needed for the additional function—for example, appropriate financial qualifications for financial responsibilities.
For someone who is not an existing Senior Manager at that club, the club must submit the temporary-appointment application and wait for written confirmation that the IFR does not object before the person starts. The club must complete baseline fitness checks, and the appointee may not take specified material decisions unilaterally. The usual limit is 12 weeks in a rolling 12-month period at the same club. However, if a full application for the same person and function is accepted as complete within that period, the temporary appointment may continue until the IFR determines—or the applicant withdraws—that application.
Beyond temporary cover: one person can permanently hold more than one SMF
The IFR Guidance addresses this point directly. Paragraph 2.24 states that an individual seeking to hold more than one SMF simultaneously must be approved for each. Paragraph 4.14 allows a single application form to list all the SMFs being sought, and paragraph 5.38 confirms that the IFR assesses competence separately for each role. Permanent combinations are therefore permitted in principle; they are not an unresolved policy question.
A Chair who will also perform the Chief Executive or Chief Finance function should identify every function the person will actually carry and obtain the required approval for each. Combining titles does not collapse the functions into one approval, and approval for one SMF is not evidence of competence for another. The assessment remains fact-specific and takes account of the role, the club’s scale and complexity, and the person’s qualifications, experience and training.
Can two people jointly carry the same SMF? It depends on the function
The ODSE Rules expressly allow joint responsibility for the Chief Executive function (SMF2): its definition covers responsibility, alone or jointly with one or more others, for the conduct and management of the whole business under the board’s immediate authority. A genuine co-Chief Executive structure can therefore fall within SMF2, with each individual requiring the appropriate approval.
That wording is not a general job-share permission for every SMF. SMF5 applies to each person acting as a director or shadow director, and more than one person may separately meet SMF6’s significant-influence test; other proposed co-lead structures must be tested against the exact definition of the relevant function and the actual allocation of responsibility. For an unusual shared Chair, finance or operations structure, the prudent course is to discuss the facts with the club’s IFR supervisor before appointment rather than assume that SMF2’s express joint wording carries across.
What delegation does, and does not, change
Delegating a task can change who performs the work, but it does not automatically change who carries the SMF. The regime looks to actual functions and responsibilities rather than job titles. If an individual continues to manage the relevant aspect of the club’s affairs or participates in the relevant decisions, delegating execution to a colleague does not, by itself, take that individual outside the SMF definition.
That is not the same as strict liability for every delegated mistake. Under paragraph 5 of Schedule 7 to the Football Governance Act 2025, a Senior Manager commits a relevant infringement where the club commits a specified relevant infringement and it is connected to the function carried out by that Senior Manager; a separate route covers breach of a commitment accepted under section 70. Under section 75, action under Schedule 9 may be taken where the IFR determines that the person committed a relevant infringement without reasonable excuse. Liability therefore turns on those statutory elements and the evidence, not a blanket rule that every delegated outcome is automatically the SMF holder’s personal infringement.
Clear governance remains important. The IFR’s Football Club Corporate Governance Code says that boards are collectively responsible for risk even where responsibilities are delegated, calls for policies that define decision-making authority and lines of accountability, and says committees should have written terms of reference while the board retains ultimate responsibility for decisions. In practice, clubs should record who may decide what, any limits or escalation triggers, the oversight applied and the decisions taken. Those records support sound governance; they do not replace the fact-specific statutory test for personal enforcement.
For the personal financial penalties, removal directions and disqualification orders that may arise under the ODSE regime, see Lagom’s existing guide to personal ODSE enforcement. For the detail of which roles may fall within the SMF6 catch-all, see Lagom’s guide to Other Key Decision Makers.
Temporary cover and permanent multi-SMF appointments now have clear rules.
Joint responsibility is function-specific, and delegation changes the workflow—not automatically the regulatory allocation or the statutory test for personal liability.
Lagom Sports Compliance is the leading specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football, globally. We support clubs through IFR licensing and enforcement -- identifying which statutory route applies, managing information and warning notices, preparing representations, and resolving concerns before licence action becomes necessary. If your club has received supervisory contact, an investigation notice, a warning notice or an urgent direction, get in touch.
For licensing, we offer:
Review Only support for clubs preparing their own application who want an independent, criterion-by-criterion review before submission;
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For ODSE specifically, we help CEOs and their leadership teams map exactly who in the organisation is in scope, assess individual readiness against the fitness and source of wealth tests, and build the material change notification process that keeps you compliant for as long as you hold the role, not just at the point of your original determination. If any of the concerns above sound genuinely familiar, get in touch and we will talk through what the right level of support looks like for your specific position.
We have also built a self service IFR readiness assessment tool. It takes around 15 minutes to complete and gives you a guide as to what you may need to, based on what you already have in place.
Frequently asked questions: multiple SMFs, delegation and temporary cover
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Yes. IFR Guidance expressly says that an individual seeking to hold more than one SMF simultaneously must be approved for each. One application form may list all the SMFs, but competence is assessed separately for every role. Separately, an existing Senior Manager may temporarily cover a colleague’s reasonably unforeseen absence under the notification route without the 12-week cap or the special decision-making limits.
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For a reasonably unforeseen absence, an existing Senior Manager at the club may take on the additional responsibilities once the club has submitted the notification form; the 12-week cap, rolling cap, baseline checks and special decision limits do not apply, although the club should ensure the person has the qualifications needed for the role and must notify the IFR when the cover ends. Someone who is not an existing Senior Manager needs a temporary-appointment application, baseline checks and the IFR’s written no-objection before starting, and is normally limited to 12 weeks in a rolling 12-month period with restrictions on specified unilateral decisions. A complete full SMF application submitted within that period can allow the cover to continue while it is determined.
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The answer is function-specific. SMF2 expressly allows Chief Executive responsibility to be held alone or jointly with one or more others, with each individual requiring approval. SMF5 may apply to multiple directors, and more than one individual may separately meet SMF6. The Rules do not give an equivalent general job-share permission for every SMF, so other co-lead structures should be tested against the precise function definition and discussed with the club’s IFR supervisor where the position is unusual.
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Delegation does not automatically change who carries the SMF: the question is who actually performs the defined function and holds or exercises the relevant responsibility. But an SMF holder is not automatically strictly liable for every delegated mistake. Personal enforcement depends on the infringement being connected to that person’s function and on the other statutory requirements, including the reasonable-excuse assessment. Clear authority, oversight, escalation and decision records remain important.
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It is finalised. The amended ODSE Rules and Guidance took effect on 5 May 2026. They are current regulatory material, not a proposal still under consultation.