Football Governance Act 2025 & IFR: Compliance Guide for Clubs

English football has a statutory regulator. It is operational. Its ownership regime has been fully live since May 2026 and every club in the top five tiers must hold an operating licence to compete from the 2027/28 season. This is not forthcoming legislation or a consultation paper. It is the law, and clubs that have not begun to engage with its requirements are already behind.

Lagom Article Header CTA

This article is brought to you by Lagom Sports Compliance -- the leading governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. We help clubs, agents and leagues navigate the IFR, UEFA licensing and EU AML obligations with proportionate, practitioner-led support.

Want to talk through what this means for your club?

Get in touch → Email us →

Key Terms Table

Key terms under the Football Governance Act 2025

Term	Meaning under the Act
The IFR	The Independent Football Regulator: the statutory body established by the Football Governance Act 2025, operational from July 2025, with full ownership powers live from 5 May 2026.
Regulated club	Any club that operates a team entered into a specified competition -- currently the Premier League, Championship, League One, League Two and National League (Step 1). All 116 clubs.
Operating licence	The licence every regulated club must hold to compete from the 2027/28 season. Provisional licences cover up to three years; full licences follow once threshold requirements are met.
Mandatory licence conditions Sch.5, s.20	Four conditions the IFR must attach to every operating licence: a financial plans condition, a corporate governance statement condition, a fan consultation condition, and an annual declaration condition.
Owner fitness criteria s.26–37	Honesty and integrity, financial soundness, and no source of wealth connected to serious criminal conduct. Applies to every owner, including prospective owners.
Officer fitness criteria s.26, s.37	Honesty and integrity, financial soundness, and requisite competence. Applies to directors, senior managers and anyone meeting the Act's definition of officer.

Why this Act exists and why it matters now

The Football Governance Act 2025 received Royal Assent on 21 July 2025. It is the product of a fan-led review that began in 2021, prompted by years of high-profile club collapses, reckless ownership decisions and the near-passage of the European Super League. The clubs whose names defined that decade of failure -- Bury, Macclesfield, Derby County, Wigan Athletic, Bolton Wanderers -- are present in the Act's preamble not by name but by implication. The legislation is explicitly designed to prevent them from happening again.

The Act's stated purpose, set out in section 1, is to protect and promote the sustainability of English football. Section 6 translates that into three operational objectives: protecting and promoting the financial soundness of individual clubs; protecting and promoting the financial resilience of the English football pyramid as a whole; and safeguarding the heritage of English football. Those three objectives are not aspirational language. They are the legal tests against which the IFR must measure every decision it makes.

The IFR itself was established as a body corporate, operationally independent from government, and drew heavily on the Financial Conduct Authority as a model. It has entered into a memorandum of understanding with the FCA to facilitate cooperation. That comparison is instructive. The FCA is not a regulator that clubs should expect to negotiate their way around. Neither is the IFR.

Which clubs are in scope, and when

The Act applies to all clubs operating a team in a specified competition. The specified competitions currently cover the top five tiers of English men's professional football: the Premier League, the Championship, League One, League Two and Step 1 of the National League. That is 116 clubs in total.

The timeline is tighter than most clubs have absorbed. The IFR has been operational since autumn 2025. Its ownership and officer suitability regime became fully live on 5 May 2026. From that date, no person may become an owner or officer of a regulated club without first obtaining an affirmative determination of suitability from the IFR.

On licensing: a pilot phase for a select group of clubs ran during summer 2026. The full application window opened in November 2026. The IFR's final licensing rules and guidance were published by 1 July 2026. Every regulated club must hold at least a provisional operating licence to compete from the 2027/28 season. Without one, operating a team in a specified competition is itself a relevant infringement under the Act.

There is no grace period built into the Act for clubs that simply did not engage with the process in time. The IFR has indicated it will take a risk-based, proportionate supervisory approach -- but proportionality in supervision is not the same as leniency toward non-compliance. Clubs that arrive at the 2027/28 season without a licence are not operating in a grey area. They are in breach.

The mandatory licence conditions: what every club must do

Schedule 5 of the Act, read with section 20, sets out four conditions that the IFR must attach to every operating licence without exception. These are not discretionary. They apply to every regulated club, at every tier, from the Premier League to the National League.

Financial plans condition. The club must submit a financial plan containing specified information to the IFR before a specified date, update that plan annually and after any material change in circumstances, and act in accordance with the latest plan submitted. The plan must include information about how the club is or will be funded, the source of that funding, expected revenues and expenses, and financial risk assessments. This is not a one-off box-ticking exercise. It is a live, ongoing obligation. A club that changes its ownership structure, takes on significant debt or faces a material financial deterioration must update its plan as soon as reasonably practicable.
Corporate governance statement condition. The club must submit a corporate governance statement to the IFR and update it at specified intervals and after material changes to governance arrangements. The statement must explain how the club is applying the IFR's governance code -- which the IFR is required to prepare and publish -- and what action the club is taking to improve equality, diversity and inclusion. The statement must also be published online. The IFR will publish every club's latest statement and produce an annual governance report assessing how well the sector is applying the code.
Fan consultation condition. The club must carry out regular consultation on relevant matters with elected fan representatives or persons the IFR considers representative of fans. The IFR has discretion over the form and frequency of consultation, calibrated to the size of the club's fanbase and its resources. This condition formalises what was previously informal and optional at most clubs. Failing to maintain meaningful fan consultation structures is now a compliance failure, not a reputational preference.
Annual declaration condition. The club must submit an annual declaration to the IFR on a specified date. The declaration must either describe any matter that should have been notified to the IFR under the Act during the preceding twelve months, or confirm that there were no such matters. This creates a recurring formal accountability mechanism with a fixed cadence.

Failure to comply with any of these conditions constitutes a relevant infringement under the Act. The consequences of relevant infringements are set out in Schedule 9 and include financial penalties of up to 10% of total club revenue, appointment of a skilled person by the IFR to assist remediation, and, in serious cases, referral to enforcement proceedings.

Owner and officer suitability: the most operationally urgent provision

Of all the Act's provisions, the owner and officer suitability regime is the one that requires the most immediate attention from clubs -- because it is already in force.

Under section 28, no person may become an owner of a regulated club unless the IFR has determined that person to be suitable. Under section 27, both the prospective owner and the club itself must notify the IFR as soon as there is a reasonable prospect of that person becoming an owner -- and must do so before the ownership transfer completes. The same obligations apply to officers under sections 27 and 29. Becoming an owner or officer without a prior affirmative determination is not a procedural technicality. It is an infringement that triggers the IFR's enforcement powers.

IFR Section 37 Criteria

What the IFR looks at: the section 37 criteria

Owners — three criteria

Honesty and integrity
Financial soundness
Source of wealth (no connection to serious criminal conduct)

Officers — three criteria

Honesty and integrity
Financial soundness
Requisite competence

s.37(2)

Honesty and integrity

Criminal convictions or proceedings anywhere in the world
Conduct outside England and Wales that would constitute a serious offence if committed here
Regulatory or disciplinary action by any body in any jurisdiction
Whether the individual is a designated person under the Sanctions and Anti-Money Laundering Act 2018
Whether the individual is prohibited from entering the UK

s.37(3)

Financial soundness

Personal insolvency history
The financial track record of any body the individual has held a position of responsibility in

Owners only

Source of wealth

If the IFR has grounds to suspect that an applicant's wealth is connected to serious criminal conduct, it must refuse the affirmative determination

This is the provision that makes robust source-of-wealth analysis essential for every ownership transaction. The threshold for refusal is suspicion, not proof.

The practical implication is significant. Every club contemplating a change of ownership or a new senior appointment must now treat IFR notification and suitability clearance as a prerequisite, not a formality to be addressed once terms are agreed. Deals that are structured without IFR engagement risk completing without the required affirmative determination -- at which point the IFR may require the owner or officer to apply retrospectively, suspend the appointment, or in serious cases issue removal directions.

The source-of-wealth provision deserves particular attention. Section 28(4)(b) requires the IFR to refuse an affirmative determination if it has grounds to suspect the applicant has any source of wealth connected to serious criminal conduct. That is a low evidential threshold for refusal, and it mirrors the language of financial crime regulation directly. Clubs receiving investment from offshore vehicles, multi-layered holding structures or jurisdictions with elevated financial crime risk should expect the IFR's scrutiny to be materially heavier than for straightforward domestic investment.

Discretionary conditions and what they mean for financially stressed clubs

Beyond the mandatory conditions, the IFR has significant discretionary powers under sections 21 to 25. It may attach additional conditions to a club's licence where it believes compliance will help the club meet the threshold requirements for a full licence or advance the IFR's systemic financial resilience objective.

Discretionary conditions relating to financial matters may address: debt management, liquidity requirements, restrictions on overall expenditure, and -- most significantly from a financial crime perspective -- restrictions on the club's ability to accept funding the IFR reasonably suspects is connected to serious criminal conduct (s.22(1)(d)).

That final provision is not a theoretical power. A club under financial pressure, actively seeking external investment and presenting a complex or opaque ownership picture to the IFR, should expect discretionary conditions around funding acceptance to be a live possibility. The IFR's section 8 regulatory principles require it to have regard to proportionality -- but proportionality works in both directions. A club presenting greater financial risk to the pyramid warrants greater regulatory attention.

Penalties: what non-compliance actually costs

Schedule 9 of the Act sets out a layered sanctions regime. For relevant infringements -- which include failure to hold a licence, failure to comply with licence conditions, breach of the ownership notification duties, and failure to comply with IFR rules -- the IFR may:

Publish a censure statement naming the club or individual, describing the infringement and explaining why publication is appropriate.

Appoint a skilled person nominated by the IFR to assist the club in ending a continuing infringement, at the club's cost.

Impose a financial penalty of up to 10% of total club revenue -- both inside and outside the United Kingdom -- as either a fixed amount or a daily rate for continuing breaches. For information-related infringements, the same 10% cap applies separately.

For senior managers: a senior manager of a club that commits a relevant infringement without reasonable excuse may themselves be subject to sanctions, including financial penalties. Personal liability for compliance failures is explicitly built into the Act's architecture.

10% Penalty Warning

The 10% figure is not a floor. It is a ceiling.

The Act caps financial penalties at 10% of total revenue. The IFR has discretion to impose less — but clubs should plan on the assumption that material non-compliance will attract material consequences, not token fines.

Premier League club

Nine-figure exposure

For a club with revenues of several hundred million pounds, 10% of total revenue is a nine-figure sum.

League Two club

Existentially significant

For a club with revenues of a few million pounds, the same 10% cap remains an existentially significant penalty.

The penalty cap applies at every tier of the regulated pyramid. No club is too small for the consequences to matter.

The IFR and EU AML 2024/1624: a converging compliance environment

English clubs now face two significant and partially overlapping regulatory frameworks simultaneously. The IFR operates domestically under the Football Governance Act 2025, covering financial soundness, ownership integrity, governance and fan engagement. EU Regulation 2024/1624 brings in-scope clubs and agents inside the AML perimeter from July 2029, with requirements covering customer due diligence, sanctions screening, source-of-wealth analysis and suspicious-activity reporting.

The overlap is not incidental. Both regimes share a core concern: the integrity of the money flowing into and through football. The IFR's source-of-wealth test for owners (s.28(4)(b)) and the AMLR's source-of-wealth obligations for counterparty transactions address the same underlying risk from different regulatory angles. A club that builds a robust ownership due diligence process for the IFR will find that process directly useful in meeting AMLR obligations. A club that does neither will face both sets of consequences.

The practical lesson is that compliance investment made now is not siloed. A defensible ownership file, a documented financial governance framework, structured fan consultation records and a trained senior management team serve the IFR, the AMLR, UEFA licensing, and the banking relationships that underpin a club's ability to function.

The IFR is not waiting. Neither should your club.

Lagom Sports Compliance is a specialist AML and financial-crime advisory firm built for professional football. The firm's work sits directly at the intersection of the Football Governance Act's ownership integrity requirements and the EU AML Regulation's due diligence obligations -- the two most consequential compliance developments in English football in a generation.

The starting point for any club uncertain about its position is the free compliance checker. It takes minutes, requires no commitment, and tells you where you stand against EU AML 2024/1624 expectations right now.

For clubs ready to move beyond the self-assessment, ourReadiness Assessment delivers a fixed-scope diagnostic: a football-specific risk mapping, gap analysis against the regulation, and a prioritised remediation roadmap that tells you exactly what a proportionate framework for your club looks like. The fee is credited in full against any subsequent implementation work.

Clubs that need a full AML framework built can explore Lagom Sports Compliance’s AML Framework Development support. For clubs that need ongoing AML support without the cost of an in-house hire, our AMLOutsourcing and Resourcing Support provides a fully outsourced AML function, the answer to a capacity problem that does not require a full-time appointment.

The regulatory environment for English football has changed permanently. The question is not whether your club needs to comply. It is whether you are doing so with enough time to do it properly.

Frequently asked questions: Football Governance Act 2025 and the Independent Football Regulator

The Football Governance Act 2025 is a UK statute that received Royal Assent on 21 July 2025. Its purpose is to protect and promote the sustainability of English football. It establishes the Independent Football Regulator (IFR), creates a mandatory operating licence regime for the top five tiers of English men's professional football, introduces an owner and officer suitability test, imposes duties on clubs and competition organisers, and creates a financial penalty and enforcement framework.
The Independent Football Regulator (IFR) is a statutory body corporate established by the Football Governance Act 2025. It has three objectives: protecting and promoting the financial soundness of individual clubs, protecting and promoting the financial resilience of English football as a whole, and safeguarding the heritage of English football. It is operationally independent of government and draws on the Financial Conduct Authority as a regulatory model. The ownership and officer suitability regime became fully operational on 5 May 2026.
The Act applies to all clubs operating a team entered into a specified competition. Currently this covers the top five tiers of English men's professional football: the Premier League, Championship, League One, League Two and Step 1 of the National League. That is currently 116 clubs in total. Women's football is not currently in scope but may be specified in future regulations by the Secretary of State.
Every regulated club must hold at least a provisional operating licence to compete from the 2027/28 season. A pilot licensing phase ran during summer 2026 for a select group of clubs. The full application window opened in November 2026. The IFR published its final licensing rules and guidance by 1 July 2026. Clubs that do not hold a licence when required are in breach of the Act.
Schedule 5 of the Act requires the IFR to attach four mandatory conditions to every operating licence: a financial plans condition (requiring submission, annual updating and compliance with a financial plan); a corporate governance statement condition (requiring submission, publication and updating of a governance statement explaining application of the IFR's governance code and equality, diversity and inclusion actions); a fan consultation condition (requiring regular consultation with fan representatives); and an annual declaration condition (requiring annual certification of compliance with notification obligations).
Under sections 27 and 28 of the Act, no person may become an owner of a regulated club without first applying to the IFR for a suitability determination. The IFR assesses three things: whether the individual has requisite honesty and integrity (considering criminal history, regulatory sanctions, sanctions designations and conduct in any jurisdiction), whether they are financially sound (considering personal insolvency history and financial track record), and whether they have any source of wealth connected to serious criminal conduct. If the IFR has grounds to suspect a source of wealth connected to serious criminal conduct, it must refuse the determination. Both the prospective owner and the club must notify the IFR as soon as there is a reasonable prospect of a change in ownership.
Yes. Under section 29, the officer fitness criteria apply to any individual meeting the Act's definition of officer, which includes directors, senior managers and others in positions of authority at a regulated club. Officers must obtain an affirmative determination of suitability before taking up their role. The criteria for officers are honesty and integrity, financial soundness and requisite competence (assessed by reference to qualifications, experience and training). Senior managers who cause or permit a club to commit a relevant infringement may themselves face personal sanctions under Schedule 9.
The Act establishes a layered sanctions regime in Schedule 9. For relevant infringements (including operating without a licence, breaching licence conditions and failing to comply with IFR notification duties), the IFR may publish a censure statement identifying the club or individual and describing the infringement; require the club to appoint a skilled person at the club's cost to assist remediation; and impose financial penalties of up to 10% of total club revenue, calculated as a fixed amount or a daily rate for continuing breaches. For information-related infringements a separate 10% cap applies. Senior managers of clubs committing relevant infringements may also face personal financial penalties.
The two frameworks address overlapping risks from different regulatory directions. The IFR's owner suitability regime, particularly the source-of-wealth test under section 28(4)(b), and the EU AMLR's source-of-wealth and beneficial ownership due diligence obligations both target financial crime risks flowing through football. A club that invests in robust ownership due diligence processes to satisfy the IFR will find those processes directly applicable to AMLR compliance. Clubs subject to both frameworks -- which in practice means most English clubs with EU transfer or commercial relationships -- should build integrated compliance frameworks rather than treating each obligation in isolation.

The Football Governance Act 2025 and the Independent Football Regulator: a compliance overview for English clubs