The final whistle on football's governance free-for-all
Patrick Davis, Head of UK Corporate Secretarial Services shares his insights on football governance.

For decades, English football has operated without a unified governance standard. Clubs registered at Companies House, leagues published their own financial reporting requirements and governance expectations, and the FA maintained the rules of the game, but no central body was responsible in a consistent manner for ensuring that the organisations running those clubs were actually fit for purpose. As long as the football was played, governance was largely an afterthought.
That era is ending.
The Football Governance Act, which received Royal Assent in July 2025, has created something that has never existed before in English football: a single, independent regulator with real teeth. The Independent Football Regulator (IFR) now has the power to license all 116 clubs across the pyramid, from Premier League title contenders to National League sides whose directors double up as programme sellers on match day. Every one of them must submit a licence application between November 2026 and February 2027.
The trigger for this change was a painfully familiar story. The insolvency of Bury FC and near-collapses at other historic clubs exposed what supporters had long suspected, that financial sustainability was being treated as someone else's problem, right up until it became everybody's problem. The Fan-Led Review of Football Governance published in November 2021, led by MP Tracey Crouch and commissioned by the previous government, made the case for a football regulator against a backdrop of European Super League proposals and drawing on the testimony of Bury supporters who had lost their clubs. The recommendation in relation to a football regulator were then taken forward and passed into law by the incoming Labour government.
The IFR has been clear that its approach will be proportionate and principles-based. A two-person board at a National League club will not be held to the same standard as the legal department of a top-six Premier League side. But proportionality does not mean optionality, and the mandatory licence conditions, covering financial sustainability, corporate governance, fan engagement and DE&I, apply across the entire pyramid.
The gulf in readiness, however, is stark.
At the top end, clubs like Chelsea, Manchester United and Liverpool have structured legal and governance functions with clearly defined responsibilities. But even within the Premier League, consistency is absent. Other top-flight clubs have no in-house lawyers at all. Drop into the Championship and qualified legal or governance professionals become genuinely rare. Further down the pyramid, record keeping is limited and formal documentation of decisions often absent.
Then there are the outliers doing things right. Lincoln City stands out as a model that clubs at any level could learn from: transparent board processes, published meeting notes, clear strategy, genuine fan engagement built into how the club is run. Brighton and Brentford, both backed by data-driven owners with backgrounds in analytical industries, have brought a rigour to squad and resource management that appears to be translating into governance practice too, with financial sustainability and fan engagement seemingly woven into the fabric of how the clubs operate, not bolted on to satisfy a regulator.
Clearly there is a spectrum of readiness and preparedness for these upcoming regulatory challenges, but there is no getting away from the fact that these obligations are coming – some will be approaching November 2026 with more confidence than others.
The clock is ticking. The IFR has signalled it wants to work with clubs, not against them. Each club will have its own dedicated relationship officer, and the regulator has been explicit that it is not in the business of shutting clubs down. But goodwill has limits, and the clubs that arrive at the licence window unprepared will find the process considerably harder than those who started early.
The governance free-for-all is over. The question now is simply: which side of the white line will your club be on?