Football Governance Licensing — Frequently Asked Questions

Who needs a licence?

Every club across the English football pyramid — all 116 of them — must obtain a licence from the Independent Football Regulator (IFR). This applies from the Premier League down to the National League. There are no exemptions based on size, revenue or league position.

When does the licensing process begin?

The application window opens in November 2026 and closes in February 2027. Pilot licensing exercises are expected to take place in summer 2026, though the clubs involved have not yet been confirmed. Clubs should not wait for the window to open before starting their preparation.

What does a licence application involve?

Each application has two core components. The first is a personnel statement, which identifies the individuals who will hold responsibility for the administration and management of the club post-licensing. The second is a strategic business plan, setting out how the club intends to operate sustainably. Both documents will need to evidence compliance with the IFR's mandatory licence conditions.

What are the mandatory licence conditions?

There are four. Financial sustainability: clubs must demonstrate that their financial plans are realistic, stress-tested and backed by credible funding. Corporate governance: clubs must comply with a governance code published by the IFR and publish an annual corporate governance statement evidencing that compliance. Fan engagement: clubs must meet minimum thresholds for meaningful supporter consultation, particularly around decisions affecting heritage assets such as the club name, crest, home colours and ground location. Diversity, equity and inclusion: DE&I standards will form part of the governance expectations the IFR applies to each club.

Will smaller clubs be held to the same standard as Premier League clubs?

No. The IFR has been clear that its approach will be proportionate and principles-based. A National League club with a small board and limited resources will not face the same expectations as a top-flight club with a large commercial operation. The principles, however, apply across the pyramid. Proportionality affects how they are met, not whether they apply at all.

What happens if a club does not meet the conditions?

The IFR has stated that it is not in the business of forcing clubs to close. Where concerns exist about a club's readiness, the expectation is that transitional arrangements will be put in place to support the club in meeting the required standards. Provisional licences will be issued initially, running for three years, before converting to a permanent licence. That said, the IFR does have significant enforcement powers, including the ability to enter premises and request records without prior notice.

What is a provisional licence and how long does it last?

Provisional licences are expected to be the initial form of licence issued following the application window. They are anticipated to run for approximately three years, during which clubs will be expected to demonstrate ongoing progress and compliance. Permanent licences will follow once the IFR is satisfied that mandatory conditions are being met consistently.

Will each club have its own contact at the IFR?

Yes. The IFR has confirmed that each of the 116 clubs will be assigned a dedicated relationship officer. The intention is that these officers will maintain an ongoing dialogue with clubs, help clarify expectations and support clubs in meeting the required standards rather than simply policing compliance from a distance.

What is the annual declaration?

In addition to the initial licence application, clubs will be required to submit an annual declaration confirming their continued compliance with the mandatory licence conditions. This is expected to cover financial sustainability, corporate governance, fan engagement and DE&I. It means licensing is not a one-off exercise. It is an ongoing obligation that requires clubs to maintain and evidence their governance standards year on year.

Where can I find out more?

The IFR is running a series of consultations in relation to different elements of  the regulatory regime introduced by the Football Governance Act, a further consultation in relation to licensing is expected in spring 2026. Law Debenture is monitoring these developments closely and will publish updates as the requirements are confirmed. In the meantime, our team is available to discuss your club's position and how to prepare.

Contact sharon.mckinney@lawdeb.com to find out more.