What does it mean to be an SMF at a football club? The IFR's ODSE regime explained

If you hold a senior role at a regulated English football club, or are about to, the Independent Football Regulator may have already assessed you. If not, it will. Since 5 May 2026, every person carrying out one of six Senior Management Functions at a regulated club requires the IFR's prior approval. That approval is personal, not delegable, and the consequences of operating without it are enforceable against you individually.

The ODSE regime: why it exists and what it covers

The Football Governance Act 2025 created the Independent Football Regulator and, with it, the Owners, Directors and Senior Executives (ODSE) regime. This regime exists because English football spent decades without any formal statutory test for who could own or run a club. The consequences -- Bury, Wigan, Derby, Bolton -- are part of the recent record. The ODSE regime is the legislative response: a formal, suspensory suitability test that applies to every owner and every Senior Management Function holder at any of the 116 regulated clubs in the top five tiers.

The regime came into full legal force on 5 May 2026. The ODSE Rules, published by the IFR in May 2026 under sections 4 and 90 of the Act, set out in detail who is in scope, what the assessment covers, how applications must be made, and what happens when circumstances change. Non-compliance with those rules may constitute a relevant infringement under Schedule 7 of the Act -- meaning it triggers the IFR's enforcement powers. This article focuses specifically on what the regime means for Senior Management Function holders rather than owners. For a full treatment of the ODSE regime covering both owners and SMFs, see the Lagom Sports Compliance ODSE overview.

The six Senior Management Functions: which one are you?

The IFR has defined six Senior Management Functions under rule 5.1 of the ODSE Rules. Anyone performing one of these functions on a permanent basis at a regulated club, a Permanent Appointee in the Rules' language, is in scope. The functions are:

Key Terms Table

Senior Management Functions under the IFR ODSE regime

Code	Function	What it covers
SMF1	Chair	Responsibility for chairing the board and overseeing its performance.
SMF2	Chief Executive	Acting as chief executive responsible for conduct and management of the whole of the club's business.
SMF3	Chief Finance	Management of financial resources, financial planning and financial reporting, including direct board reporting.
SMF4	Chief Operations	Overall responsibility for managing all, or substantially all, of the club’s internal operations.
SMF5	Director	Acting as a registered or registrable director under section 250 of the Companies Act 2006, or as a shadow director.
SMF6	Other Key Decision Maker	Having a significant influence on the management or conduct of one or more aspects of the club’s affairs in relation to its regulated activities -- the catch-all for influential individuals outside SMF1 to SMF5.

SMF6 deserves particular attention. It is the catch-all function: anyone with significant influence over the management or conduct of one or more aspects of the club's regulated activities, even if they do not hold any of the five named roles. A major investor who sits on no board but exercises influence over commercial or footballing decisions; a beneficial owner's representative who attends board meetings in an advisory capacity; a senior figure exercising de facto authority without a formal title -- all of these are candidates for SMF6 classification. The IFR has been explicit that simply because a role is not included in the illustrative examples does not mean it is out of scope. The determining factor is substance, not label.

The three-part suitability test

Before anyone can take up a Specified Senior Management Function as a Permanent Appointee, the IFR must determine them to be suitable. The suitability test under rule 4 of the ODSE Rules and section 37 of the Act has three components: honesty and integrity, financial soundness, and requisite competence.

On honesty and integrity, the IFR must have regard to a wide range of factors (rule 4.2). These include: criminal convictions or proceedings anywhere in the world, not just in England and Wales; 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; and whether the individual, or a sporting entity in which they held a position of responsibility, has been subject to disciplinary or enforcement action by any sporting authority or has failed to comply with any direction or order set by a sporting authority or competition organiser.
On financial soundness, the IFR considers personal insolvency history -- bankruptcy, individual voluntary arrangements, sequestration or equivalent procedures anywhere in the world -- and the financial track record of any body in which the individual held a position of responsibility (rule 4.3). An applicant whose prior employer went into administration under their tenure will face scrutiny on this point, even if they were not personally responsible for the outcome.
On requisite competence, the IFR assesses qualifications, experience and training relevant to the function being applied for (rule 4.4). This component does not apply to owners, only to SMF holders, and it means that the IFR expects to see a demonstrable professional basis for the appointment, not simply personal relationships with the club's ownership.

Exemption Warning Box

The exemption is not yours to grant yourself

The most common misreading of the regulation among smaller clubs is treating the Article 5 exemption as if it is a default. It is not. Under Article 5, Member States may exempt certain clubs -- but only on the basis of a formal national risk assessment demonstrating proven low risk. The exemption is granted by a supervisory authority following that process. It is not claimed by the club on its own initiative.

A club that assumes it is exempt, without having engaged with the national supervisory authority and without having been formally notified of an exemption decision, is not exempt. It is non-compliant.

What happens when circumstances change: the ongoing obligation

Obtaining an affirmative determination is not the end of the compliance obligation. It is the beginning of it. Once approved, an SMF holder carries a continuing duty to notify the IFR of any material change in circumstances that is relevant to their suitability.

Under rule 6.2 of the ODSE Rules, an individual who is a Senior Manager must notify the IFR where they consider there has been, or may have been, a material change in circumstances relevant to their suitability. Rule 6.3 imposes the same obligation on the club in relation to its Senior Managers. Both notifications must be made as soon as reasonably practicable (rule 6.5).

The circumstances that trigger this duty are those that would be material to the original assessment. A criminal investigation anywhere in the world; a regulatory or disciplinary action by any body; a personal insolvency event; a material adverse change in the financial position of another entity in which the SMF holds a position of responsibility; a sanctions designation, all of these are likely to constitute material changes requiring prompt notification. The duty is self-initiating: the SMF holder cannot wait for the IFR to ask. They must volunteer the information.

When an SMF holder ceases to perform their function, the club must notify the IFR within 20 working days of the individual ceasing to perform that function (rule 5.4). The notification must also confirm who is carrying out the functions previously undertaken by the departing SMF holder. Failure to notify constitutes a relevant infringement.

The personal liability question: what Schedule 9 actually says

The most significant aspect of the SMF regime for individual senior managers is one that is rarely discussed clearly: personal financial liability. The Football Governance Act 2025 does not only create penalties for clubs. It creates penalties for individuals.

Schedule 9 of the Act sets out the IFR's sanctions powers. For relevant infringements -- which include a club operating without a licence, breaching licence conditions, breaching ODSE notification duties, and failing to comply with IFR rules -- the IFR may impose financial penalties. The cap for relevant infringements is 10% of the club's total revenue. That is a club-level penalty. But the Act goes further.

A senior manager of a club that commits a relevant infringement may themselves be subject to a financial penalty where they caused or permitted the infringement without reasonable excuse. The personal penalty cap is also set at 10% of the relevant revenue figure -- for an individual, that is likely to be calculated by reference to their remuneration. For a highly paid CEO or CFO at a Championship or Premier League club, this is not a nominal sum. It is a material personal financial consequence.

Beyond financial penalties, the IFR also has the power to publish censure statements naming individuals. There is no quiet resolution mechanism: every censure statement is published. The reputational consequences of being named in an IFR enforcement action, independently of any financial penalty, are severe in a sector where personal reputation is a professional asset.

Personal Liability Callout

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The Act does not only create penalties for clubs. It creates penalties for individuals. A senior manager who caused or permitted a relevant infringement may face personal financial consequences, and there is no quiet resolution.

The case for directors' and officers' insurance: connecting the dots

Directors' and officers' (D&O) insurance is not mentioned in the Football Governance Act 2025 or the ODSE Rules. The IFR does not require clubs to hold it. But the personal liability framework in Schedule 9, combined with the breadth of the suitability assessment under rule 4 and the ongoing notification duties under rule 6, creates a risk profile for individual SMF holders that is materially different from anything that existed before 5 May 2026.

Consider what a senior manager now faces.

Their past -- including regulatory actions, litigation and the financial track record of every entity in which they ever held a position of responsibility -- is permanently visible to the IFR and is a live part of their ongoing suitability.
Their present -- any material change in circumstances, including events in their personal financial position or the position of other entities they are connected to, must be reported promptly.
Their future decisions — any failure by the club to comply with IFR rules that they caused or permitted, may result in a personal financial penalty and a published censure statement.

D&O insurance exists precisely to address this combination of circumstances: the cost of responding to regulatory investigations, the legal costs of any enforcement proceedings, the financial consequences of personal liability findings, and the reputational management that follows adverse regulatory outcomes. A SMF holder at a regulated football club who does not hold adequate D&O cover, whether personally or through a club policy, is carrying a level of uninsured personal financial risk that has no precedent in English football's recent history.

The argument is not that every SMF will face enforcement action. Most will not. The argument is that the cost of being wrong about that has increased significantly since 5 May 2026 -- and that the cost of D&O cover is, in virtually every case, modest relative to the personal financial exposure that Schedule 9 creates. Any senior manager who has taken legal advice on their ODSE application should ensure that the same advice session addresses their insurance position. Any club that has assisted its SMF holders with the application process should ensure it has also considered the adequacy of its D&O programme.

Temporary appointments: the 12-week rule

Not every SMF appointment is permanent. The ODSE Rules create a specific mechanism for temporary cover: situations where an existing SMF holder has an unforeseen absence and someone needs to step in. Under rule 5.8, an individual may be appointed to a Senior Management Function on a temporary basis without prior IFR approval, but only within strict parameters.

The appointment must cover a reasonably unforeseen absence. The individual must be appointed solely for that purpose. And the temporary appointment must not exceed 12 weeks in any consecutive 12-month period, unless, within that 12-week window, a full application has been submitted to the IFR and a determination is still pending. During the temporary appointment, the individual is also restricted from making unilateral decisions on matters affecting the club's financial or strategic position, material asset disposals, or ownership structure changes (rule 5.8(c)).

Crucially, the club must notify the IFR of any proposed temporary appointment before it takes effect, using the IFR's prescribed form, and may not proceed until the IFR confirms in writing that it does not object (rule 5.10). This is not a mere formality. The IFR's non-objection notice is a prerequisite. Acting without it is a relevant infringement.

Your determination is personal. The preparation should be too.

Lagom Sports Compliance works with football clubs and their senior executives on ODSE applications, suitability preparation and ongoing compliance obligations under the IFR regime.

The firm supports individuals preparing for the IFR's assessment as well as clubs managing the ODSE process for multiple SMF holders simultaneously.

For dedicated IFR compliance support, see lagomsportscompliance.com/ifr-compliance-for-english-football-clubs.

Contact us today to see how we can advise clubs as well as the SMFs that run then.

The IFR's public register of ODSE determinations is updated weekly. Your name may already be on it. If it is not yet and it should be, the clock is running.

Frequently asked questions: SMFs and the IFR ODSE regime

An SMF, Senior Management Function, is one of six defined roles at a regulated English football club that require prior approval from the Independent Football Regulator before the individual can take up the position. The six functions are: SMF1 (Chair), SMF2 (Chief Executive), SMF3 (Chief Finance), SMF4 (Chief Operations), SMF5 (Director), and SMF6 (Other Key Decision Maker). The SMF regime was created under the Football Governance Act 2025 and came into force on 5 May 2026 as part of the IFR's ODSE regime.
Yes, if the role constitutes one of the six Specified Senior Management Functions under the ODSE Rules. Under rule 3.3 of the IFR's ODSE Rules, an individual may not take on a position that would be a Specified Senior Management Function at a regulated club unless an application has been made to the IFR and the IFR has determined them to be suitable. There is no grace period and no informal workaround. The appointment cannot take effect until the IFR's affirmative determination has been received. Both the individual and the club must notify the IFR as soon as there is a reasonable prospect of the appointment.
The IFR assesses three things: honesty and integrity, financial soundness, and requisite competence. On honesty and integrity, the IFR considers criminal convictions or proceedings anywhere in the world, regulatory or disciplinary actions by any body in any jurisdiction, sanctions designations under the Sanctions and Anti-Money Laundering Act 2018, and whether the individual or any sporting entity in which they held a position of responsibility has been subject to enforcement action or failed to comply with requirements from any sporting authority or competition organiser. On financial soundness, the IFR considers personal insolvency history and the financial track record of any body in which the individual held a position of responsibility. On requisite competence, the IFR assesses qualifications, experience and training relevant to the specific function.
SMF6 is the Other Key Decision Maker function. It applies to any individual who has a significant influence on the management or conduct of one or more aspects of a regulated club's affairs in relation to its regulated activities, even where they do not hold any of the five named senior roles. This is a deliberately broad catch-all category. A major investor exercising practical influence over club decisions without a formal title, a beneficial owner's representative attending board meetings in an advisory capacity, or any senior figure exercising de facto authority without a formal appointment may all fall within SMF6. The IFR has confirmed that the determining factor is whether the individual has a continued and high degree of decision-making authority over the club's regulated activities, not their formal job title.
Yes. Under Schedule 9 of the Football Governance Act 2025, a senior manager of a club that commits a relevant infringement may themselves face a personal financial penalty where they caused or permitted the infringement without reasonable excuse. The personal penalty is calculated by reference to the relevant revenue figure for the individual. In addition, the IFR may publish a censure statement naming the individual and describing the infringement. There is no private resolution mechanism: all censure statements are published. This personal liability framework is one of the reasons that directors' and officers' insurance is now a material consideration for any individual holding an SMF at a regulated club.
Under rule 5.8 of the ODSE Rules, an individual may be appointed to a Senior Management Function on a temporary basis to cover a reasonably unforeseen absence without prior IFR approval, provided: the appointment is solely to cover that unforeseen absence; the individual does not carry out the functions for more than 12 weeks in any consecutive 12-month period (unless a full application has been submitted and a determination is still pending); and the individual does not make unilateral decisions on material financial commitments, asset disposals or ownership structure changes. The club must still notify the IFR before the appointment takes effect using the prescribed Temporary Appointment Application Form and may not proceed until the IFR confirms it does not object.
An SMF holder must notify the IFR as soon as reasonably practicable of any material change in circumstances relevant to their suitability -- including criminal investigations, regulatory actions, insolvency events, or material adverse changes in entities in which they hold a position of responsibility. The club is under the same obligation in relation to its SMF holders. When an SMF holder ceases to perform their function, the club must notify the IFR within 20 working days and confirm who is covering those functions. Failure to comply with notification obligations constitutes a relevant infringement under Schedule 7 of the Act.
The IFR maintains a public register of all ODSE determinations, which it aims to update on a weekly basis. The register is available at footballregulator.org.uk/odse-determinations.