Horizon Scanning: Our predictions for the future of football regulation
Football regulation is not being built from a blank page. Almost every mechanism now appearing in the IFR's licensing framework and the EU's approach to football-specific AML has a direct precedent somewhere in financial services regulation over the past fifteen years. That is not a coincidence, it is the natural result of governments and regulators reaching for tools that have already been tested elsewhere, rather than inventing football-specific ones from scratch. Reading that precedent carefully lets us make some genuinely informed predictions about where football regulation goes next. These are our own views, not confirmed policy, and we have graded our confidence in each one accordingly.
Almost every mechanism now appearing in football regulation has a direct precedent in financial services. That is the lens through which these predictions are made.
1. A formal IFR Skilled Persons Panel
Under Schedule 9 of the Football Governance Act 2025, the IFR can require a club to appoint a skilled person it nominates -- but the Act, as currently drafted, describes this as a case-by-case nomination rather than an appointment from any published, pre-vetted panel. The FCA's equivalent power under section 166 of FSMA operated the same way in its early years. It does not operate that way now.
The FCA has since built a formal Skilled Persons Panel, organised into eight distinct 'Lots' by regulatory specialism -- client assets, financial crime and others -- populated by pre-approved accountancy and legal firms the FCA can draw from directly, or that a firm can select from with the regulator's agreement. The volume of section 166 reviews has grown substantially in recent years, and a formal panel structure is a natural, almost inevitable response to that growth: it is faster, more consistent, and easier for both the regulator and the firms involved to manage than sourcing a suitably skilled, conflict-free nominee from scratch every time.
We expect the IFR to move in the same direction as skilled person appointments become more frequent. A formal, football-specific panel -- likely organised by specialism (financial sustainability, governance, ownership integrity, fan engagement) in a structure similar to the FCA's Lots -- would be the logical next step once the current ad hoc nomination model starts to show the same strain the FCA's did.
2. Operational resilience becomes an explicit expectation
Nothing in the IFR's current mandatory licence conditions names operational resilience as a distinct discipline in the way the FCA's PS21/3 framework does for financial services -- important business services, impact tolerances, mapping, scenario testing. But the underlying concern PS21/3 was built to address -- that firms delivering critical services to the public had not properly stress-tested their own ability to withstand serious disruption -- applies with very little modification to football clubs, and the financial plans and governance conditions already in the IFR's framework are reaching in that direction without yet naming it explicitly.
We think it is a reasonably likely development, over time, that the IFR's supervisory expectations -- whether through guidance, discretionary licence conditions, or a future amendment to the mandatory conditions -- begin to name operational resilience specifically, following the same path PS21/3 took in financial services: starting as supervisory expectation and general good practice, then hardening into an explicit, named requirement. We would not be surprised to see this emerge first as informal supervisory expectation before it becomes a formal condition.
3. A UK-specific AML framework for football, possibly involving HMRC
The EU's AMLR brings football clubs and agents within its obliged-entity regime from 10 July 2029 -- but that is an EU regulation, and it does not, in itself, create an equivalent obligation for clubs and agents operating purely within the UK. The UK's own Money Laundering Regulations 2017 currently designate specific sectors -- estate agency, trust and company service provision, high-value dealers -- to specific supervisors, HMRC among the most prominent for sectors outside the FCA's direct remit.
We think it is plausible, though by no means certain, that the UK moves toward an equivalent AML framework for football specifically, rather than leaving UK clubs and agents entirely outside a formal AML supervisory perimeter while their EU counterparts are brought fully inside one. Whether that supervisory role sits with the IFR directly, is delegated to or shared with HMRC in the way other non-FCA sectors are supervised, or takes some other form entirely, is genuinely uncertain -- but the structural gap between the EU's approach and the UK's current position is real, and gaps of this kind in adjacent, closely linked markets do not tend to persist indefinitely once one side has moved.
4. The IFR halts a club sale, not just delays one
The IFR's owner suitability regime already gives it the power to determine that a prospective owner does not meet the fitness or source-of-wealth test, and to refuse an affirmative determination on that basis. To date, public commentary on the regime has focused overwhelmingly on the additional time and evidence a transaction now requires -- the deal-timeline extension effect -- rather than on the possibility of a transaction being stopped outright.
We think it is a realistic prediction, not a remote one, that within a reasonably short timeframe the IFR moves beyond slowing transactions down and actually halts one in its entirety on suitability grounds -- refusing a determination outright rather than simply extending the timeline while further evidence is gathered. Regulators that build a suitability-testing power and then never actually use it to say no tend not to retain credibility for that power over the medium term. We would expect the IFR, at some point, to demonstrate that this power has real teeth, not just administrative friction.
5. Divergent AMLR implementation across national football associations
AMLR is a directly applicable EU regulation, meaning it does not require domestic transposing legislation in each member state in the way an EU directive would. In principle, this should produce uniform application across the bloc. In practice, EU financial regulation has repeatedly shown that a single rulebook and consistent national supervision are two different things -- MiFID II is the clearest precedent, where ESMA sets the overarching framework but individual national regulators have historically applied guidance, enforcement priorities and interpretive nuance differently enough that firms operating across multiple member states routinely need jurisdiction-specific compliance advice, not just a single EU-wide policy.
AMLA, the EU's new Anti-Money Laundering Authority, exists partly because this exact divergence problem has already been identified as a weakness in AML supervision generally; its own mandate explicitly includes a coordination and convergence role specifically because national supervisors have not historically applied AML rules consistently. Football is now entering that same structure for the first time, through national football associations and national AML supervisors that have no prior experience regulating the sport for financial crime specifically. We think it is highly likely that individual EU member states' football associations and national AML supervisors interpret and apply AMLR's football-specific provisions with meaningfully different emphasis, pace and enforcement style in the years immediately following the 2029 application date -- exactly the pattern AMLA itself was built to eventually correct, not prevent from ever occurring.
6. Beneficial ownership transparency becomes the sharpest area of focus
Beneficial ownership verification is already a core AMLR obligation, not a future addition -- it does not need a new rule to exist. What we expect to change is the intensity of practical focus on it, driven by two converging pressures. First, AMLR's own due diligence requirements will simply make beneficial ownership questions unavoidable for any club or agent bringing a transaction within scope. Second, and more significantly, if football's ownership market continues its current trajectory of increasing multi-club groups, complex fund structures and cross-border investment vehicles, beneficial ownership will be the single area where the gap between what a straightforward ownership structure requires and what a genuinely complex one requires becomes most visible, most quickly.
We think beneficial ownership transparency, more than any other single AMLR obligation, is where regulatory attention concentrates disproportionately over the coming years -- not because the rule itself is new, but because the market it is being applied to is becoming structurally more opaque at exactly the moment the rule requires it to become more transparent.
7. An ODSE-equivalent regime emerges elsewhere in Europe
England's ODSE regime -- individual suitability testing for owners, directors and senior executives, assessed against fitness and source-of-wealth criteria -- is, to our knowledge, the most developed statutory version of this kind of individual accountability testing anywhere in European football. UEFA's own licensing framework addresses financial sustainability and, to a lesser extent, ownership disclosure, but nothing at UEFA level currently mirrors the individual, person-by-person suitability determination the IFR now applies in England.
We think it is a reasonably likely medium-term development that at least one other major European football market, or UEFA itself at competition level, introduces some version of individual owner and officer suitability testing modelled on the English approach -- not because of any formal obligation to do so, but because regulatory frameworks of this kind tend to migrate between comparable markets once one jurisdiction has demonstrated the mechanism can actually be built and operated. English football has effectively run the pilot. Whether that produces a fully harmonised European standard, or a patchwork of individual national versions each built slightly differently, is much less certain than the direction of travel itself.
8. AI enters the regulatory conversation, in a form not yet clear
This is the prediction we are least confident in, and we want to be honest about that rather than manufacture false certainty. Artificial intelligence is increasingly present in football's own operations -- performance analysis, scouting, commercial and fan engagement tools, and, plausibly, compliance and due diligence functions themselves. Financial services regulators have begun grappling with AI governance directly, from model risk management expectations to broader questions about accountability for AI-assisted decisions.
We think AI will become part of football's regulatory conversation in some form. What we do not think we can credibly predict is the specific shape that takes -- whether it appears as a governance expectation around how clubs themselves use AI in decision-making, as a due diligence question about AI tools used by counterparties, as a data protection and fan-data concern, or as something else entirely that has not yet become visible in the sector. This is genuinely the one prediction on this list we would ask readers to treat as a placeholder for a real and coming issue, rather than a specific forecast of its form.
A final word on why these predictions, and why now
None of these eight predictions should be read as certainties, and we have deliberately graded our confidence in each rather than presenting them with uniform authority. What connects all eight, and what we think is the genuinely useful takeaway regardless of how any individual prediction plays out, is the method behind them: football regulation is following a path financial services regulation has already walked, often closely enough that the next step is visible well before it is confirmed. Clubs, agents and investors who treat football regulation as an entirely novel, unprecedented domain are missing the most useful available signal for what is coming. Those who read it against its financial services antecedents have a genuine head start.
About Lagom Sports Compliance
Lagom Sports Compliance is the UK's specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. We track the intersection of football regulation and financial services precedent closely, precisely because that intersection is where we believe the most reliable signal for what comes next actually lives. If you want to discuss how any of these predictions might affect your own club, agency or investment position, get in touch.
Frequently asked questions: the future of football regulation
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The IFR's owner suitability regime already gives it the legal power to refuse an affirmative suitability determination on fitness or source-of-wealth grounds, which would prevent a proposed acquisition completing. As of the date of this article, public commentary has focused mainly on transactions being delayed or made more complex, rather than an outright refusal. Lagom's own view is that it is a high-confidence prediction that the IFR halts a transaction outright within a reasonably short timeframe, on the basis that a suitability-testing power that is never actually exercised to say no tends not to retain credibility over time. This is Lagom's own forward-looking opinion, not a report of a confirmed or announced IFR decision.
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This is one of our higher-confidence predictions. While AMLR is a directly applicable EU regulation, EU financial regulation has a well-documented pattern -- most visibly under MiFID II -- of a single rulebook producing meaningfully different national supervisory practice, guidance and enforcement style. The EU's new AMLA authority exists partly because this divergence problem has already been identified as a weakness in AML supervision generally, and its own mandate explicitly includes a convergence role for exactly this reason. Football is entering this structure for the first time through national associations and supervisors with no prior football-specific AML experience, which Lagom expects will produce visible divergence in the years immediately following the 2029 application date.
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England's ODSE regime is, to our knowledge, currently the most developed individual owner and officer suitability testing framework in European football. Lagom's medium-confidence prediction is that at least one other major European market, or UEFA itself, introduces a comparable individual suitability regime over the medium term, on the basis that regulatory mechanisms of this kind tend to migrate between comparable markets once one jurisdiction has demonstrated they can be built and operated. Whether this produces a single harmonised European standard or a patchwork of differently designed national versions is considerably less certain than the general direction of travel.
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Not currently, in the way the EU's AMLR will apply to clubs and agents operating within the EU from 10 July 2029. AMLR is an EU regulation and does not itself create an equivalent obligation for UK-only clubs and agents. Our high-confidence prediction is that the UK moves toward an equivalent football-specific AML framework over time, potentially involving HMRC given its existing role supervising other UK sectors outside the FCA's direct remit under the UK Money Laundering Regulations 2017 -- though the precise form this might take, including whether it involves the IFR, HMRC, or another body, is genuinely uncertain.
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Confidence varies across the eight predictions, and each one is explicitly graded as High Confidence, Medium Confidence or Speculative. Six predictions are graded High Confidence: a formal IFR skilled persons panel, operational resilience becoming an explicit expectation, a UK-specific AML framework for football, the IFR halting a club sale outright, divergent national implementation of AMLR across the EU, and beneficial ownership transparency becoming the sharpest area of focus -- all reflecting well-established financial services precedent. One prediction, an ODSE-equivalent regime emerging elsewhere in Europe, is graded Medium Confidence. The prediction on the future role of AI in football regulation is explicitly flagged as Speculative, reflecting genuine uncertainty about the specific form it will take, even though Lagom expects the underlying issue to become relevant.