The Independent Football Regulator ("IFR")'s powers took another significant step forward on 5 May 2026, as a raft of provisions under the Football Governance Act 2025 ("FGA") came into force through the Football Governance Act 2025 (Commencement No. 3) Regulations 2026. These provisions switch on additional elements of the owners, directors and senior executives ("ODSE") suitability regime and impose new duties on clubs.
Additional powers under the ODSE regime
Firstly, clubs and individuals must now notify the IFR of any prospective new owner or officer, kicking off a formal determination process. The rule is straightforward: no person may become an owner or officer of a regulated club unless the IFR has determined that they are suitable for the role. Those who attempt to sidestep the process, by becoming an owner or officer without first obtaining such a determination, will face regulatory consequences.
Fairness, though, is built into the system. An individual facing a proposed negative determination must be given an opportunity to make representations before any final decision is taken (section 31). Statutory time limits for making a determination also apply: the IFR has 90 days to reach an initial determination, extendable by up to 60 days in complex cases, giving a maximum window of 150 days .
Crucially, the ODSE regime is not confined to newcomers. The IFR already held powers to review incumbent owners and incumbent officers where concerns about suitability emerge. The IFR can remove owners and officers it considers unsuitable, and in the most extreme cases, it can apply for ownership removal orders under section 43 of the FGA, a last-resort power enabling the appointment of trustees to bring about a forced change in club ownership.
For further insight into the implications of the ODSE regime, please see our previous articles on the implications for owners and senior managers respectively.
New duties on clubs and competition organisers
Part 5 of the FGA also gained further teeth on 5 May.
Clubs must now obtain IFR approval before disposing of or dealing with their home ground, a safeguard that places heritage assets firmly under the regulator's watch. They may not appoint an administrator without IFR approval either, a provision that only clubs teetering on the edge of financial collapse may need to consider.
Football fans, too, have gained a new statutory right. Section 51 of the FGA obliges clubs to keep fans informed during insolvency proceedings, recognising the significance of such proceedings to fans and the club's community.
Finally, under section 55 of the FGA, the Premier League, English Football League and National League now owe duties to notify and consult the IFR in certain circumstances, for example, where they suspect that a club has breached a competition rule which is relevant to the IFR's functions, or prior to imposing a penalty or sanction in connection with such a breach. These obligations reinforce the regulator's position as a central oversight body in the governance of English football.
What does this mean in practice?
For prospective investors and incoming directors, the message is clear: no key personnel appointments or club takeovers should proceed without engaging the IFR's formal approval process. For clubs, compliance teams must ensure that notification obligations are met promptly, and that heritage assets, particularly home grounds, are not dealt with without regulatory sign-off.
The IFR has signaled its intention to take an interventionist approach where financial sustainability is at risk, and with these provisions now live, it has the statutory tools to do so. The degree and manner of intervention remain to be seen. As the regulator seeks to establish itself, its likely starting point will be to encourage a healthy dialogue with clubs and to foster collaboration. However, where clubs refuse to cooperate or fail to abide by the FGA, we may well see the IFR exercise its enforcement powers in earnest. For further insight into how the IFR's close alignment with the Financial Conduct Authority may shape the exercise of its powers, please see our article here.
If you are looking for guidance on how the IFR may react to issues and/or exercise its powers, please contact your usual Lewis Silkin contact, or the author.
