Lagom Sports Compliance published in Football Stadium Management on fan engagement as a licensing condition
Jonathan Greenstein, Co-founder and Director of Lagom Sports Compliance, has been published in Football Stadium Management (FSM) in the August / September 2026 issue and online. The article examines a change that many clubs have yet to fully absorb: under the Football Governance Act 2025, fan engagement has moved from a matter of club discretion to a mandatory condition of the Independent Football Regulator’s operating licence.
What we covered in the article
Under Schedule 5 of the Football Governance Act 2025, the IFR is required to attach a fan consultation condition to every operating licence it issues. That captures all 116 regulated clubs across the Premier League, Championship, League One, League Two and National League Step 1. The condition requires regular, documented consultation with elected fan representatives, or with persons the IFR considers representative of the club’s supporter base, and it binds a club from the moment its licence comes into force, including a provisional licence.
The piece sets out what that means operationally rather than in principle. It draws the distinction between communication and consultation, which is the distinction between talking at supporters and listening to them, and it identifies the three things clubs need in place:
A genuinely representative structure, not a self-selected group and not a body whose membership the club controls.
A documented process, with agendas, records of fan input and evidence of how that input was considered.
A closed loop on outcomes, demonstrating what changed as a result of consultation and, where fan views were overridden, why.
It also addresses the questions operations and governance professionals are actually asking, including whether existing supporter trusts and fan advisory boards will satisfy the regulator, what constitutes a relevant matter for consultation, and how fan engagement evidence will surface in the corporate governance statement that Schedule 5 also requires clubs to publish.
The commercial argument
The article makes the case that regulatory compliance and commercial performance point in the same direction here. Clubs with robust, two-way supporter relationships are better positioned with sponsors, broadcasters and partners who price fan loyalty into their propositions, and they are less exposed to the kind of commercial partnership that damages fan trust and attracts regulatory scrutiny at the same time. The Financial Conduct Authority’s June 2026 letter to Premier League clubs, warning about partnerships with unauthorised financial firms, is a live illustration of that overlap.
“The IFR has created a regulatory requirement. The operational and commercial opportunity is there for any club willing to approach it as more than a compliance exercise.”
Jonathan Greenstein, Co-founder and Director, Lagom Sports Compliance
Read the article
The full feature is available on the FSM website and in the August / September 2026 digital issue.
Lagom Sports Compliance is a specialist governance, risk, compliance and anti-financial crime consultancy built exclusively for professional football. The firm advises clubs, agents and agencies on IFR licensing readiness, governance framework design and anti-financial crime obligations across the English and European game.
Frequently asked questions
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The fan consultation condition is one of four mandatory conditions the Independent Football Regulator must attach to every operating licence under Schedule 5 of the Football Governance Act 2025. It requires a regulated club to carry out regular, documented consultation with elected fan representatives, or with persons the IFR considers representative of its supporter base, on matters relevant to the club. The requirement is for structured consultation rather than communication: the club must seek fan input, consider it, and be able to demonstrate how engagement outcomes were accounted for.
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It applies to all 116 regulated clubs across the Premier League, Championship, League One, League Two and National League Step 1. The form and frequency of consultation will be calibrated to the size of the club’s fanbase and its resources, so a Premier League club and a National League club will not face identical expectations. Proportionality affects how the obligation is met, not whether it applies.
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The condition attaches from the moment a club’s operating licence comes into force. A club holding a provisional licence is bound by its mandatory conditions immediately, not at some later point when it transitions to a full licence. Every regulated club must hold at least a provisional operating licence to compete from the 2027/28 season.
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Schedule 5 sets out four mandatory conditions. The financial plans condition requires the club to submit a financial plan, update it annually and after material changes, and act in accordance with it. The corporate governance statement condition requires the club to submit, publish and update a statement explaining how it applies the IFR’s governance code and what it is doing on equality, diversity and inclusion. The fan consultation condition requires regular, structured and documented engagement with fan representatives. The annual declaration condition requires yearly certification that the club has met its IFR notification obligations, or confirmation that there was nothing to notify.
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Not automatically. The IFR will want to see that the people being consulted are genuinely representative of the fanbase, rather than a self-selected group, an exclusively season-ticket-holder body, or a structure whose membership is controlled by the club. Many clubs already have supporter trust relationships or fan advisory boards. The question is whether those structures are properly constituted, independently chaired and capable of providing genuine rather than performative input.
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Every consultation meeting, agenda item, record of fan input and note of the decision that followed should be in writing. This is governance infrastructure rather than administrative paperwork. The club’s annual declaration to the IFR will need to certify that consultation obligations have been met, and that certification is only defensible if the underlying documentation exists. Fan engagement evidence will also form part of the public record created by the corporate governance statement condition.
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The article, titled Fan Engagement Is Now A Licensing Condition: What The Football Governance Act 2025 Means For Stadium And Club Operations, is published on the Football Stadium Management website and appears in the August / September 2026 issue.