The Football Governance Act 2025 created a statutory regulator with powers no football club has previously had to answer to. The Independent Football Regulator can require licensing, examine ownership, demand financial information, and take action against clubs that fail to meet its standards. Most clubs are operationally unprepared. The work to be ready is administrative, structural, and cannot be done at the last minute.
Football has been regulated by football for a long time. The leagues set the rules. The leagues enforce the rules. The disputes are heard within football's own machinery. Clubs have grown up assuming that the standard for compliance is whatever the league happens to ask for, and that the worst case for non-compliance is a points deduction or a fine paid to a body the club's owner already knows.
The Football Governance Act 2025 ended that.
The Act created the Independent Football Regulator, a statutory body with the powers of a regulator in the technical sense, not the colloquial one. The IFR can require clubs to be licensed in order to compete. It can examine the people who own and run clubs. It can demand financial information and act on what it finds. It can take action that affects whether a club operates at all.
For most clubs, this is a category change in how the club is governed. Few are ready for it.
The IFR has four broad areas of authority. The first is licensing. Clubs in scope require a licence to compete. The licence is conditional on meeting standards across financial sustainability, ownership and governance, and supporter engagement. The licence can be granted, renewed, varied, or revoked. There is no equivalent in football's previous regulatory history.
The second is the ownership and directors test. The IFR examines the people who own and run a club, and can determine that an individual is not suitable. The test is not the same as the league's existing fit and proper person tests. It is more rigorous, conducted by a different body, and capable of producing different conclusions about the same individuals.
The third is financial regulation. The IFR can require financial information, examine financial sustainability, and act on financial concerns. The owner-financed model that has supported parts of the football pyramid for decades is not banned, but it is now subject to scrutiny in a way it was not before.
The fourth is the broader category of cultural and supporter protection. Heritage assets, club identity, the relationship between owners and supporters, all are now within the regulator's interest in a way that was previously left to football's own informal arrangements.
The first thing clubs need is a structural mapping of who actually owns the club. This sounds obvious. It is not. Many clubs are owned through layered structures involving holding companies, trusts, foundations, and individual shareholders across multiple jurisdictions. The structure was often set up for tax, asset protection, or commercial reasons that made sense at the time, and has not been examined holistically since. The IFR's ownership test requires the club to know who its ultimate beneficial owners are, what control they exercise, and what their broader business and personal background contains.
The second is documentation of the financial position. Not the position the auditor signs off on at year end. The position the regulator will want to examine, which includes related party transactions, owner funding arrangements, contingent liabilities, and the dependence of the club on funding sources that may or may not continue to be available. Clubs that cannot quickly produce this picture are running a risk that their first encounter with the regulator becomes a discovery exercise rather than a presentation exercise.
The third is the governance map. Who makes decisions, what kinds of decisions they make, what the formal process is for those decisions, and what the actual practice has been. The IFR will examine the gap between formal governance and operational reality. Clubs with strong written governance and weak operational discipline are exposed.
The fourth is the counterparty diligence work. Clubs do business with agents, intermediaries, sponsors, lenders, and commercial partners. The standards expected for understanding those relationships are higher under the new regime than they have been historically. Clubs that have not done meaningful counterparty due diligence on their commercial book are sitting on risk they have not measured.
The fifth is the ODSE submission preparation. The Owners' and Directors' Suitability Examination process requires clubs to provide structured information about ownership and senior leadership in a defined format. Clubs that wait to be asked are at a disadvantage relative to clubs that have prepared the information in advance.
The first exposure is structural opacity. A club whose ownership runs through entities in jurisdictions that do not maintain public beneficial ownership records is going to need to produce evidence the regulator can rely on, and that evidence may not exist in a form the regulator will accept. The work to remediate that is slow, requires legal input across multiple jurisdictions, and cannot be compressed.
The second is owner conduct history. The IFR's suitability assessment looks at whether owners have been involved in regulatory action, insolvency events, or other matters that bear on suitability. Clubs whose owners have a complex past and have not previously had to disclose it in this format face a process they may not be prepared for.
The third is financial dependence. Clubs that rely on owner funding without formal documentation, intra-group loans without arm's-length terms, or commercial arrangements that depend on related parties, all face questions about whether the club is financially sustainable in the regulator's sense.
The fourth is the governance-reality gap. Clubs that have written governance frameworks but operate informally are going to have to close the gap quickly, and the closing is more painful when the regulator is already looking.
A club that is ready for the IFR has done five things.
It has mapped its ownership structure end to end and can explain it to a regulator. It has documented the financial position in a form that supports an external review. It has aligned its governance documentation with operational practice and can show the alignment. It has done meaningful counterparty diligence on its commercial book. And it has prepared the ODSE submission in advance of being asked.
None of this is football work. It is regulated firm work, applied to football. The clubs that recognise that early are going to find the transition manageable. The clubs that wait are going to find their first conversation with the regulator is also their first conversation with the regulator about why they cannot answer questions the regulator is entitled to ask.
| Area | What needs to be in place |
|---|---|
| Ownership mapping | End-to-end beneficial ownership documented and evidenced |
| Financial documentation | Sustainability picture including related parties and contingent liabilities |
| Governance map | Written framework matching operational practice |
| Counterparty diligence | Understanding of agents, intermediaries, and commercial partners |
| ODSE preparation | Submission-ready information on owners and senior leadership |
Vexil is a governance and diligence platform for football organisations handling licensing, ownership suitability, counterparty risk, and ODSE submissions under the Independent Football Regulator regime established by the Football Governance Act 2025.