The Football Governance Act 2025 created the Independent Football Regulator with statutory powers no football club has previously had to answer to. The IFR can require licensing, examine ownership, demand financial information, and act on what it finds. Most clubs are operationally unprepared for the category change in how they will now be governed.
On 21 July 2025, the Football Governance Act received Royal Assent and the Independent Football Regulator came into existence. For the first time in English football's history, there is a statutory regulator with powers to licence clubs, approve owners and senior executives, demand information on pain of criminal sanction, and remove unsuitable custodians. The regime is being phased in, but the direction is set. By the 2027/28 season, every club in the top five tiers of English football will require an operating licence.
The ODSE regime, covering Owners, Directors and Senior Executives, has already applied to incumbent owners and senior managers since December 2025. From May 2026, it applies to new appointments. Every prospective owner or senior manager must pass the test before taking the role, against statutory criteria covering honesty and integrity, financial soundness, source of wealth, and, for officers, competence. No-one takes up ownership or a senior management function until the IFR has decided they are suitable.
This is not a consultation paper or a proposed framework. It is the law, and it is in force now.
The clubs most immediately affected are Championship clubs. Twenty-four clubs with significant sponsorship portfolios, active transfer windows, cross-border player movement, and a realistic promotion ceiling that exposes them to the full weight of Premier League IFR scrutiny. Most have a company secretary or commercial director nominally responsible for compliance. Most have never produced a defensible counterparty due diligence file. Most have never run a fit-and-proper assessment against documented criteria, never written a corporate governance statement they expect a regulator to read, and never had to demonstrate to an external authority how they reached a decision about an owner, a sponsor, or a transfer counterparty.
Sheffield Wednesday entered administration in October 2025 after its owner failed to pay staff and HMRC for five months. The club was docked 12 points by the EFL and its former owner was banned from football for three years. This happened under the old, lighter-touch regime. Under the IFR, the outcomes would be different, the scrutiny more intensive, and the burden of demonstrating that the club took appropriate steps much higher.
Lower Premier League clubs face the same obligations with a fraction of the in-house compliance capacity of the top six. The regulatory requirement is identical whether you are Manchester City or a newly promoted club with 15 commercial staff. The IFR does not scale its expectations to the size of the organisation.
For clubs in League One, League Two, and the National League Step One, the challenge is different in character but equally significant. Smaller counterparty volumes, lower transfer activity, fewer complex ownership structures, and essentially no compliance capability at all. These clubs will struggle to meet IFR licensing requirements not because the requirements are unreasonable, but because they have never had to think about compliance in anything like this way before. The company secretary who also runs HR and facilities management is now nominally responsible for producing ODSE submissions, counterparty risk assessments, and corporate governance documentation that a statutory regulator will read and judge.
Agents face a separate but related challenge. Over 2,400 FA-registered agents now operate under new FIFA Football Agent Regulations, published fee and transaction reporting obligations, and growing AML expectations as the sector moves toward obliged-entity status. Most agents are sole traders or small partnerships. Most have no AML framework, no documented CDD process, and no ability to produce a counterparty risk assessment for the clubs and players they represent. The regulatory direction is clear: football intermediaries are moving toward the same compliance expectations as financial intermediaries, and the timeline for that convergence is shortening.
The question that matters most for clubs, agents, and the sports lawyers and advisors who work with them is not what the IFR requires in principle. That is documented. The question is what it will actually look like in practice when the regulator starts asking clubs to demonstrate their compliance.
Based on how equivalent regulatory regimes operate in financial services, the IFR will be interested in several things that football organisations have historically not thought about. First, the quality of the reasoning behind counterparty decisions. Deciding to take on a sponsorship partner, approve an owner, or proceed with a transfer counterparty is not the same as being able to demonstrate, with a documented and defensible record, how that decision was reached, what information was considered, what red flags were identified and addressed, and who was responsible for the outcome.
Second, ongoing monitoring rather than point-in-time assessment. A sponsor who was clean at onboarding may not be clean two years later. An agent whose owner structure was simple when they were first engaged may have changed considerably since. The IFR regime, like AML regimes in financial services, will expect clubs and agents to maintain monitoring arrangements that catch material changes, not just to conduct initial due diligence and file the result.
Third, governance documentation that is genuine rather than performative. A corporate governance statement that was written to satisfy a checklist is a different document from one that was written to explain how the club actually makes decisions, who has authority for what, and how conflicts of interest are managed. The IFR will be able to tell the difference.
This is exactly the problem that Vexil is designed to address. It is a governance and diligence platform built specifically for the IFR regime, giving clubs, agents, and advisors a structured way to produce the counterparty assessments, ODSE submissions, and governance documentation the regulator will ask for, without requiring them to build a compliance function from scratch.
The clubs and advisors that are preparing now, building the documentation and the decision infrastructure before the IFR starts asking, will be in a fundamentally different position to those that wait until the regulator arrives. In financial services, the firms that fare best under regulatory scrutiny are rarely the ones that responded fastest after the event. They are the ones that built something defensible before it was needed.
Football is now a regulated environment. The clubs and advisors who treat it like one from the start will be the ones who find the IFR manageable when it looks closely at how they operate.
Vexil is a governance and diligence platform for football organisations handling licensing, ownership suitability, counterparty risk, and ODSE submissions under the Football Governance Act 2025.