1.2 | Timeline – When do I need to prepare?

21 Jul 2025
Following on from the 2021 fan-led review of the football governance system, the Football Governance Act (FGA) 2025 gains Royal Assent, establishing IFR to oversee financial sustainability, governance, and fan engagement in English men’s professional football

4 Sep 2025
IFR consultations (all closed 6 October 2025) on:
• Owners, Directors and Senior Executives (ODSE) Regime
• Information Gathering and Enforcement
• Sanctions

Oct 2025
David Kogan appointed IFR Chair and Richard Monks appointed IFR CEO IFR consultations on:
• Internal Review Function (closed 10 Nov)
• Licensing Regime (closed 8 Dec)

Nov 2025
FGA (Commencement No. 1) Regulations 2025, bring into force FGA provisions giving IFR information gathering powers:
• Power to require information: FGA, Clause 65
• IFR can appoint ‘expert reporters’ to prepare and provide IFR with a report in relation to a regulated club on any matter it deems necessary for the purpose of exercising its functions under the FGA: FGA, Clause 66

24 Nov 2025
Commencement of FGA (Specified Competitions) Regulations 2025, formally granting IFR power to regulate top five tiers of English men’s professional football

5 Dec 2025
IFR publishes responses to consultations on ODSE Regime and Information Gathering and Enforcement

8 Dec 2025
DCMS statutory guidance on “significant influence or control” under Schedule 1 FGA (relevant to IFR’s suitability test of individuals or registered societies who own or propose to acquire regulated clubs)

12 Dec 2025
FGA (Commencement No. 2) Regulations 2025 give IFR powers to use sanctions such as public censure statements and financial penalties against clubs, owners, officers and competition organisers. FGA, Clause 75 and Schedule 9

20 January 2026
Consultation on State of the Game report Terms of Reference

Spring 2026
IFR plans to publish second consultation on Licensing Regime

May 2026
New owners, directors and senior executives will need to meet ODSE Regime thresholds (12 December 2025 for incumbent owners)

Summer 2026
IFR expects to publish final rules and guidance on its Licensing Regime

Mid-Late 2026
IFR aims to publish the draft State of the Game Report (with final report due in 2027) , providing overview of main issues affecting English football and an assessment of whether any features of the market threaten the IFR’s ability to advance its objectives. It is expected to be a broad assessment of the financial health, market structure, and economic issues in the football industry

Nov 2026 to Feb 2027
IFR intends to open applications for clubs to submit first licence applications ahead of 2027/28 season

2027/28
Clubs required to secure provisional IFR licence ahead of the 27/28 season