The Independent Football Regulator is coming — is your club ready?

The Independent Football Regulator (IFR) is no longer a policy paper or a parliamentary debate. The Football Governance Act 2025 is now law, the regulator is being established and the regulatory timetable is moving.

If your club hasn’t started preparing, you’re already behind. If you have, this guide will help you sense-check whether you’re on track.

This is a practical briefing for CEOs, CFOs, general counsel, club secretaries and ownership teams who need to understand the immediate decisions: how to respond to consultations, how to prepare for the levy, whether to join the pilot scheme and how to build a durable IFR compliance strategy.

Phase one: the immediate board agenda

IFR readiness should now be firmly on the board agenda. Clubs don’t need every detail of the final regime to start preparing, but they do need a disciplined view of their current position, key gaps and the decisions that can’t wait.

Governance health check

Review your existing governance structures against the standards anticipated by the Act. This includes board composition, conflicts of interest policies, decision-making processes and the quality of corporate records. The IFR will have powers to assess whether clubs meet the threshold requirements for a licence. If your governance is patchy, it’s far better to identify that now than when the regulator comes knocking.

Financial sustainability self-assessment

Financial sustainability sits at the heart of the new regime. Clubs should already have stress-tested their financial position, reviewed cash flow forecasting and assessed reliance on owner funding. If your club’s finances wouldn’t survive a searching external review, now is the time to understand why.

Stress-test cash flow, owner funding, debt exposure, working capital, transfer commitments and downside scenarios. The question isn’t simply whether the club can balance this season’s budget; it’s whether the financial model can withstand scrutiny from a regulator focused on long-term sustainability.

Ownership and director suitability

The IFR will operate its own owners’ and directors’ test, distinct from – and likely more demanding than – existing FA, EFL and Premier League frameworks. Directors, significant shareholders and other persons of significant influence should be benchmarked against the suitability criteria set out in the Act.

Identify the information likely to be required, test any sensitive issues early and avoid discovering problems for the first time during a formal regulatory process.

Engagement with existing regulators

Clubs should ensure compliance with current FA, EFL and Premier League requirements is up to date and robust. The IFR won’t operate in a vacuum; it will build on existing regulatory information and gaps or failings under the current system will be noticed.

Phase two: consultations – shape the rules before they harden

This is where much of the real work sits. Three immediate priorities demand attention. The IFR consultation process is one of the most important near-term opportunities for clubs to influence how the new regime will work in practice. It should be treated as a strategic exercise, not a delegated compliance task.

Consultation responses: don’t sit it out

The IFR has been consulting on key aspects of its regulatory framework., and these consultations aren’t box-ticking exercises. The regulator is actively shaping the detail of how it will operate — from licensing conditions and financial requirements to reporting obligations — and what clubs say now will genuinely influence the outcome.

Practical advice: engage constructively, not defensively. Blanket objections or narrow self-interest will carry less weight than thoughtful, evidence-based input. Flag practical implementation issues, such as how proposed reporting timelines interact with season-end audit cycles or how particular financial metrics may affect certain club ownership structures. Be specific, constructive and, crucially, actually respond. Non-engagement is a missed opportunity to shape the rules you’ll have to live by.

The pilot scheme — should you join?

The IFR is shortly commencing a pilot scheme, and clubs will need to decide whether to participate. This isn’t simply about being seen as cooperative. It’s a practical decision about timing, readiness, management capacity and regulatory exposure.

Pros: Early engagement can help build a constructive relationship with the regulator. Pilot participants will gain early insight into how licensing and reporting will work in practice, giving them a head start on compliance. There’s also a reputational benefit in signalling a serious approach to governance. Perhaps most importantly, participants may help identify practical problems before they become binding requirements.

Cons: The pilot will require management time and carries an element of uncertainty as the IFR refines its approach. It may expose issues before they’ve been fully remediated. Clubs shouldn’t volunteer for closer scrutiny without understanding what the regulator is likely to see.

The steer: Clubs with reasonably mature governance and financial reporting should seriously consider joining. Decisions shouldn’t be made in the abstract. A focused IFR readiness check should come first. We can support that process through readiness reviews, governance and financial reporting gap audits, board briefings and remediation plans, so clubs can make a confident decision on whether to participate and how to manage the process if they do.

The levy — what it is and what to do about it

The IFR has the power to fund itself through a levy on regulated clubs. In plain terms, clubs will contribute financially to the cost of their own regulation. The precise structure is still being developed, but it’s expected to be broadly proportionate, with clubs in higher tiers bearing a larger share.

The detail of allocation and methodology matters: it will affect budgets, cash flow and financial planning and, for some clubs, may reduce headroom for squad, infrastructure and operational investment.

What clubs should do now is build the levy into financial planning. Even without a confirmed figure, work through a range of scenarios and ensure budgets for the 2026/27 season and beyond account for this new cost. For clubs operating on tight margins, this isn’t trivial. Engagement with the levy consultation is an important opportunity to influence how the burden is shared.

Phase three: what to do during the 2026/27 season

Over the 2026/27 season, IFR readiness should move from project mode into business-as-usual governance. Clubs best placed to manage the regime will be those that embed compliance into board reporting, finance processes and strategic planning.

Licensing preparation

The IFR will operate a licensing system requiring clubs to meet prescribed conditions. While detail is still emerging, clubs should map anticipated requirements against current operations and develop realistic remediation plans where gaps exist.

Enhanced financial reporting

Expect more demanding financial reporting obligations than most clubs currently face. This may require investment in finance teams, systems and processes, and a review of whether existing auditors and advisers have the capacity and expertise to support the transition.

Ongoing owners’ and directors’ compliance

The IFR’s test will be ongoing, not a one-off hurdle. Clubs should implement internal processes to monitor the continuing suitability of directors and owners, including regular self-declarations and clear protocols for reporting material changes to the regulator.

Building internal regulatory capability

Every club should appoint a named IFR lead to coordinate the internal response, brief the board and manage relationships with advisers and the regulator.

The board’s 30-day action plan

In the next 30 days, clubs should do five things:

1. Respond to open IFR consultations, ensuring submissions are constructive and specific to make sure your club’s voice is heard
2. Decide on pilot participation only after completing a readiness check
3. Build a realistic IFR levy provision into 2026/27 financial planning
4. Appoint an internal IFR lead and identify which external advisers will support legal, financial and governance workstreams
5. Commission an IFR readiness audit to identify gaps, prioritise remediation and create a clear board paper on the club’s regulatory risk profile.

The IFR shouldn’t be seen as a threat to well-run clubs. It does, however, represent a significant change in the regulatory landscape. Clubs that prepare early, engage openly and evidence their position will be better placed to protect their licence, reputation and strategic freedom. The time to act is now.