2 | The IFR – What it does
Why was the IFR established?
Created under the Football Governance Act 2025 (FGA), the IFR was established to protect and promote the sustainability of English football, independently from government and football authorities. The new statutory system does not replace the existing framework comprised of contractual and public law principles that apply to private limited companies, like The FA or the Premier League. The statutory system is intended to complement these frameworks.
The stated core role of the IFR is to regulate the financial sustainability of clubs and the leagues in which they compete. In scope are the 116 clubs in the top five men’s professional leagues: the Premier League, EFL Championship, League One and League Two, and the Men’s National League. While the women’s game is currently out of scope, the impact of the IFR will still impact those women’s clubs who have a corresponding men’s team who are in-scope (for example, Owners, Directors and Senior Executives (ODSEs) rules, tests and declarations will likely lead to overlapping submissions, considerations and compliance checks).
The IFR has, while operating in pursuit of its primary objectives, a duty to consider other “secondary” outcomes that are important in the football industry but are not the direct responsibility of the IFR.
These include:
- sporting competition;
- the competitiveness of regulated clubs; and
- growth of and investment into English football.
The IFR must consider these outcomes and seek to avoid disrupting them where possible.
Impact on clubs
The IFR will operate a licensing regime and monitor/enforce compliance on financial regulation, fan engagement and club heritage. The Secretary of State for Culture, Media and Sport, Lisa Nandy, described this in 2025 as giving supporters a meaningful say in key decisions, such as stadium relocation and club identity (name, badge, home colours). Clubs must have an effective framework in place to regularly meet fans to discuss strategic matters and other issues of interest to supporters such as ticketing, operational and match-day issues, and the club’s strategic direction.
Clubs will also be required to adhere to tougher financial regulation with their long-term sustainability said to be at the heart of this. Clubs will be required to demonstrate sound basic financial practices, maintain appropriate financial resources to meet cash flows including in the event of financial shock, and protect core assets such as the stadium. The IFR will have the power to place bespoke conditions on clubs to mitigate concerning levels of financial risk. It will be able to require owners to sell clubs and appoint third parties to help run clubs as trustees (it being anticipated that these trustees may move to place clubs into administration if necessary to help facilitate a sale). Each club must publish a governance statement explaining how it meets standards of transparency, accountability, and board oversight.
The FGA gives the IFR the power to assess and determine the suitability of prospective new owners and “officers” and, under certain circumstances, incumbent owners and “officers” of regulated club. A new and enhanced ODSE test is being implemented with investors and leaders now required to demonstrate financial soundness and competence so they can be good custodians for clubs. For example, owners would need permission from the IFR to sell or borrow against the club’s stadium.
The ODSE provisions came into force on 12 December 2025, with transitional arrangements for incumbent owners and office-holders, and mandatory pre-approval for all new owners, directors, and specified senior executives due to apply from May 2026. The powers that the IFR will have through the ODSE regime are seen as an essential element of its duties that will allow it to enforce its rules efficiently and uphold standards across the game.
The IFR will also have the authority to prohibit clubs from joining non-meritocratic or closed competitions, which is its way of preventing clubs joining “breakaway leagues” that it considers to fall within that bracket (such as the attempted European Super League in the form proposed in 2021).
Backstop powers may also be used to ensure fair distribution of broadcast revenue between leagues (the Premier League and the EFL) where agreement on this cannot be reached. Talks on distribution will still take place within football, but there is a mechanism that, if triggered, would bring the regulator into those discussions initially on a mediation basis, and if that’s not successful, on a determination basis.
Looking to the future
State of the game and guidance coming
Section 10 of the FGA requires the IFR to prepare and publish a “State of the Game” report. This report will provide an overview of main issues affecting English football including financial sustainability and club heritage. It will cover issues such as broadcast revenues, player wages, club ownership, financial distributions and academy development. Topics such as ticket prices and Video Assistant Referees are outside its scope. The IFR is able to utilise its statutory powers to access the information it needs from clubs and competition organisers to produce the report.
Prior to publishing the final version, the IFR must prepare and consult on the draft report. The consultation on the report's terms of reference opened on 20 January, closing on 17 February 2026.
To assist clubs in meeting the IFR’s expectations, it will continue to publish new and updated practical guidance, including on licensing processes, sanctions and decision-making procedures.
On the horizon – enforcement and sanctions
From 12 December 2025 the IFR can investigate any current owner in the top 5 tiers of men’s football in England. The IFR will have the power to enforce compliance through financial penalties, public censure, and in extreme cases, forcing an owner to sell.
For more detail on enforcement see links to section 4 below:
4 | The IFR enforcement links
Looking to the future
State of the game and guidance coming
Section 10 of the FGA requires the IFR to prepare and publish a “State of the Game” report. This report will provide an overview of main issues affecting English football including financial sustainability and club heritage. It will cover issues such as broadcast revenues, player wages, club ownership, financial distributions and academy development. Topics such as ticket prices and Video Assistant Referees are outside its scope. The IFR is able to utilise its statutory powers to access the information it needs from clubs and competition organisers to produce the report.
Prior to publishing the final version, the IFR must prepare and consult on the draft report. The consultation on the report's terms of reference opened on 20 January, closing on 17 February 2026.
To assist clubs in meeting the IFR’s expectations, it will continue to publish new and updated practical guidance, including on licensing processes, sanctions and decision-making procedures.
On the horizon – enforcement and sanctions
From 12 December 2025 the IFR can investigate any current owner in the top 5 tiers of men’s football in England. The IFR will have the power to enforce compliance through financial penalties, public censure, and in extreme cases, forcing an owner to sell.
For more detail on enforcement see links to section 4 below: