IFR publishes Temporary Appointments and ODSE Response Document

On 1 May 2026, the IFR published its response to the consultation on Temporary Appointments and ODSE Amendments (CP1/26). The finalised rules and guidance, which took effect on 5 May 2026, refine the Owners, Directors and Senior Executives (ODSE) regime and introduce changes to the temporary appointments provision for Senior Management Functions where there is an unforeseen absence.

Key Changes and Clarifications

The IFR has implemented several refinements to the regime following stakeholder feedback:

• 12-Week Temporary Provision: Clubs can now appoint individuals to cover Senior Management Function (“SMF”) roles for up to 12 weeks without full IFR approval in the event of a genuinely unforeseen absence, such as sudden ill health or an immediate resignation.
• Extension Mechanism: To avoid a “cliff edge,” a temporary appointment can extend beyond 12 weeks if a full SMF application for that individual has been submitted and accepted as complete by the IFR before the initial period expires.
• Individual Flexibility: The 12-week limit is now club-specific rather than individual-specific; an individual may serve a 12-week temporary term at multiple different regulated clubs within the same year, though they remain capped at 12 weeks per year for any single club.
• Decision-Making Boundaries: While temporary appointees can handle routine operational matters (e.g., payroll, matchday security), they are restricted from unilaterally approving major financial commitments, asset disposals, or ownership changes unless they obtain dual sign-off from an approved Senior Manager or the club's board.
• “Function over Form” Scope: The Regulator clarified that an individual is defined as an “officer” based on their actual influence and decision-making authority rather than their job title. This mapping includes six specific Senior Management Functions (SMFs).
• Baseline Suitability Checks: For temporary staff who are not existing Senior Managers, the IFR requires clubs to perform their own baseline fitness checks, including right-to-work verification and self-certified declarations regarding criminal convictions and bankruptcy.

Procedural Implementation & Next Steps

The ODSE regime has applied to incumbent owners and managers since December 2025. However, as of May 2026, all prospective owners and senior managers must pass the IFR's suitability assessment before acquiring control of a club or taking up their position.

Clubs must notify the IFR as soon as there is a “reasonable prospect” of an appointment or acquisition. The IFR is subject to a statutory 90-day limit to make a determination on complete applications, which can be extended to 150 days in exceptional circumstances. Each club is now assigned a dedicated IFR supervisor to assist with these notifications and provide direct support during recruitment or transaction processes.

IFR publishes Sanctions Response Document & Final Guidance

On 12 December 2025, the IFR published its response to the consultation on draft Sanctions Guidance and its final guidance, Sanctions Guidance (IFR 3/2025). Following feedback, the IFR has finalised the framework it will use to determine penalties for breaches of the Football Governance Act. The final guidance maintains a “stepped approach” comprising

Step 1: Seriousness,

Step 2: Adjustments,

Step 3: Proportionality, and

Step 4: Statutory Caps

to ensure that penalties are consistent, transparent, and proportionate to each specific case.

Key Changes and Clarifications

While the core methodology remains largely the same, the IFR has implemented several amendments directly addressing concerns raised during the consultation:

• Protections for Smaller Clubs: When assessing the seriousness of a breach at Step 1, the IFR will now explicitly account for the extent to which a club’s size and resource limitations contributed to the failure.
• Defining “Relevant Revenue”: The IFR clarified exactly which revenue streams determine the "starting point" for a fine.
  • Included: Matchday income, broadcasting, sponsorship, grant income for day-to-day operations, and solidarity/parachute payments.
  • Excluded: Revenue generated from player transfers and direct owner funding.
• New “Revenue Rules” (Annex 2): To ensure transparency at Step 4, the IFR has published formal rules for calculating the 10% statutory cap. These rules clarify how the IFR determines total and daily revenue, including the requirement to look at the revenue of a club’s entire corporate group when calculating the maximum permitted penalty.
• Fan Engagement as a Factor: Reflecting the importance of fans in the new regime, a failure to engage with them may now be treated as an aggravating factor at Step 2 if that lack of engagement contributed to the breach.
• Safeguards Against “Double-Counting”: The IFR added an explicit commitment (and footnote) to avoid penalising a club twice for the same factor across different steps of the calculation.
• Financial Hardship: While an adverse financial situation is not an automatic excuse, the IFR may reduce a penalty or provide more time to pay in exceptional cases of severe financial hardship.

IFR publishes CP1/25 Owners, Directors & Senior Executives (ODSE) Response Document

On 5 December 2025 the IFR published its response to the feedback received during its consultation on how the IFR proposes to establish and oversee the Owners, Directors & Senior Executives (ODSE) regime as set out in Part 4 of the FGA.

The final ODSE rules, guidance, and application forms were also published on 5 December 2025, forming the basis of the ODSE regime. The IFR was able to consider the suitability of incumbent owners from 12 December 2025 and will receive powers to test suitability of new applicants from May 2026.

In response the IFR made:

• Changes to the draft rules, amending the definition of the Chief Operations Officer function (SMF4) to refine the scope following industry feedback. The IFR also amended the title of the proposed Significant Influence function (SMF6) to Other Key Decision Maker function (SMF6).
• Amendments to the draft guidance including: