The Independent Football Regulator (IFR) between 17 March and 10 April 2026 consulted on changes covering two distinct areas: (i) temporary appointments to Senior Management Functions (SMFs) during unforeseen absences, and (ii) a series of technical and clarificatory amendments to the Owners, Directors and Senior Executives (ODSE) regime. It published its response on 1 May 2026, with changes effective from 5 May 2026.

The changes carry practical implications for clubs, investors and senior individuals across the beautiful game. We appreciate that the volume and detail of the IFR's evolving regulatory framework can feel complex and extensive. With that in mind, we have set out a brief executive summary of the key changes below, and then a longer piece delving into the latest regime changes in more detail. Here's what you need to know.

Executive summary

Temporary appointments: Clubs may now appoint an individual to a Senior Management Function on a temporary basis for up to 12 weeks without full IFR approval, provided the absence is genuinely unforeseen. Temporary IFR approval is however still required where the individual providing cover is not already an approved Senior Manager. Five conditions apply, covering (i) the nature of the absence, (ii) the 12-week cap on temporary appointments, (iii) notification to the IFR, (iv) the club's own suitability assessment of the appointee, and (v) restrictions on the temporary appointee's ability to make significant unilateral decisions. Where an existing approved Senior Manager absorbs the absent person's duties, no time limit or decision-making restrictions apply - the club need only notify the IFR.

ODSE technical amendments: The IFR has introduced a series of clarifications to the ODSE regime, including: incorporating the statutory time limits for suitability assessments (90 days, extendable to 150 days in exceptional circumstances); updating guidance on who counts as an "owner" by reference to the broad "significant influence or control" test under the Football Governance Act 2025 (FGA); setting out a process for withdrawing applications; aligning the financial resources assessment with proposed licensing requirements (including a three-year financial planning horizon); and clarifying who qualifies as an "incumbent" under the transitional provisions (i.e. anyone who became an owner or officer before 21 July 2025).

What should clubs do now? Clubs should begin planning how they would operationalise a temporary appointment at short notice, including identifying who would carry out suitability checks and what governance protocols need to be in place. Clubs should also note that the IFR's final licensing rules and guidance are due to be published by 1 July 2026.

The changes in more detail

1. Temporary appointments for unforeseen absences

What happens when a Senior Manager (whether a CEO, finance director or other senior role) suddenly becomes unavailable due to ill health, emergency suspension or an abrupt departure? 

The answer is that clubs may appoint someone to an SMF role on a temporary basis for up to 12 weeks without needing to obtain full IFR approval in advance, however temporary IFR approval must be obtained if the individual providing cover is not already approved by the IFR as an SMF. It is somewhat frustrating for stakeholders that IFR approval is needed for temporary cover by non-SMFs, given the IFR 12-week rule appears largely to be modelled on the Financial Conduct Authority's 12-week rule for FCA SMFs but the FCA does not require such notification and approval.

The proposal is subject to five conditions, designed to prevent misuse while giving clubs the operational flexibility they need. 

1. The provision applies only to genuinely unforeseen absences. The IFR has signalled that patterns of use suggesting absences were in fact foreseeable will attract supervisory scrutiny and potentially formal enforcement action. The IFR has provided guidance and illustrative examples of what constitutes an 'unforeseen absence'.  These include sudden ill-health, bereavement, immediate suspension or regulation. Planned parental leave is not an unforeseen absence.  Clubs should have appropriate succession planning and recruitment processes in place for foreseen absences.
2. The appointment is capped at 12 weeks in any 12-month period, on a per-club basis. If the absence is likely to extend beyond that, the club must apply for full SMF approval as soon as reasonably practicable, and the temporary appointment may only continue beyond 12 weeks where that application is already pending.
3. Clubs must notify the IFR using a new draft notification form (all temporary appointees), and the IFR will have 14 days to communicate its decision (temporary appointees that are not already senior managers). There is no specific deadline for notifying, but in practical terms it should be done as soon as possible as the person cannot start performing the role prior to notification/approval.
4. The onus is on the club, not the IFR, to assess the temporary appointee's experience, qualifications and competence, and to provide a declaration to the IFR confirming that the club considers the person meets suitability standards. For individuals who are not already approved Senior Managers, clubs must also verify their identity and right to work in the UK, and obtain self-certified declarations covering criminal convictions, sanctions, bankruptcy and director disqualifications.
5. Temporary appointees will face restrictions on their ability to make significant decisions –no unilateral decisions concerning: financial or other commitments in relation to the regulated club that are likely to materially affect the club's financial or strategic position (causing it to deviate from its financial plan or strategic business plan); disposal/long-term leasing/granting security over material club assets; material alterations to a club's ownership structure, allocation of equity/voting rights, or board composition (save for internal approval of the temporary appointment).  For urgent decisions that cannot be taken unilaterally by the temporary appointee, the options include dual-sign off with an existing permanent senior manager at the club, escalation to the club's board for approval, or the board setting a pre-approved strategy, financial limits or principles with which the temporary appointee must comply. 

Importantly, where an existing approved Senior Manager takes on the absent individual's responsibilities, no 12-week time limit applies. The club need only notify the IFR and confirm the individual has the qualifications and competence for the extra duties. No reassessment of suitability is needed and there are no restrictions on decision-making.

Notifications for non-SMF temporary appointees must be made on the IFR Temporary Appointments application form; for SMF temporary appointees the notification must be made on the IFR Temporary Appointments notification form.  The regulated club must further notify the IFR in writing as soon as reasonably practicable after the Temporary Appointee ceases to carry out the relevant functions.

2. Technical amendments to the ODSE regime

The second limb of the consultation addresses a series of technical and clarificatory amendments to the ODSE guidance and rules, first published in December 2025. 

Suitability assessment time limits

Secondary legislation (namely, the Football Governance Act 2025 (Suitability Determination Period for Owners and Officers) Regulations 2026) sets out specific statutory time limits within which the IFR must determine ODSE suitability applications - 90 days beginning on the day after it receives the application, extendable in exceptional circumstances to a maximum of 150 days. The IFR's guidance now helpfully sets out these timescales, and gives examples of what may constitute exceptional circumstances – including material changes in an individual's circumstances in particular late in the process, delays to validating information with other agencies, complex ownership structures, and lack of co-operation from the applicant.

Significant influence and control – who counts as an "owner"?

One of the more nuanced aspects of the Football Governance Act 2025 (FGA) is its broad definition of "owner", which extends well beyond straightforward share ownership. Under the FGA, any individual who can exercise significant influence or control over a regulated club may be captured. 

In December 2025, the IFR published statutory guidance unpacking what that means in practice. Three key themes emerged.

• First, the guidance makes clear that a person may be regarded as exercising significant influence or control where they hold the power to make binding decisions or to block critical matters relating to a club's operations. That could include changes for example to financial plans, the appointment of new sponsors, the renaming of the club's home stadium, or the disposal of major assets. Crucially, the individual does not need to have actually exercised those powers - the mere existence of such rights is enough.
• Second, a person will also be treated as an owner where they wield significant influence or control in practice, even without any formal right to do so. The guidance gives the example of a financial arrangement with the club that means other owners or officers routinely act on the person's directions or suggestions, or a situation in which an individual's personal connections with key figures at the club give them a degree of practical authority that goes beyond their formal role.
• Third, the guidance confirms that a person cannot avoid classification as an owner simply by channeling their influence or control through a trust or another intermediary structure. There are, however, a number of "excepted roles" (e.g. professional advisers) whose involvement with a club would not, by itself, bring them within scope.

The IFR has now updated the ODSE guidance to reference this statutory guidance. Importantly, no new tests or thresholds are being introduced - assessments will continue on a case-by-case basis within the existing statutory framework.

Withdrawing applications

Applicants will need to notify the IFR of the withdrawal, and once the IFR has verified there is no longer a reasonable prospect that the person will become an owner or Senior Manager, the application will no longer be treated as "duly made" under the rules.

Clarifications on sufficient financial resources

The clarifications have been made to align the ODSE regime guidance and application forms with the proposed licensing requirements for clubs.  The IFR's assessment  for prospective owners includes the target club's circumstances and the prospective owner's intentions and strategy – which must show that the target club will be able to meet its obligations for at least three full financial years, each running from 1 July to 30 June.  Prospective owners are also required to provide a financial and business plan, including details of source of funds.

Who counts as an "incumbent"?

Because the FGA was brought into effect in stages, there was scope for ambiguity as to which individuals fell within the transitional provisions. A new rule has therefore been added to clarify who qualifies as an incumbent Owner, Director or Senior Executive under the ODSE regime - essentially, anyone who is an owner or officer of a regulated club (as defined in the FGA) and became so before 21 July 2025.

What's next?

For clubs, the temporary appointments framework in particular offers a practical solution to a genuine governance gap, but the conditions attached, particularly around notification, due diligence and decision-making restrictions, will require careful internal planning. Clubs should consider now how they would operationalise a temporary appointment at short notice, including who would carry out the required suitability checks and what governance protocols would need to be in place.

In addition, regulated clubs, prospective owners and senior managers should be aware that the IFR's final licensing rules and guidance are due to be published by 1 July 2026. 

If you would like to discuss any of the above or need strategic advice on engaging with the IFR and the new regime, please get in touch with your usual Lewis Silkin contact or a member of the Lewis Silkin IFR team.