English football’s approach to vetting the people who run its clubs has changed fundamentally.

According to Argus Pro, the Owners’ and Directors’ Suitability and Experience (ODSE) test took effect on 12 December 2025, making it the first live component of the Independent Football Regulator’s (IFR) new regime. Clubs that have not yet mapped their exposure are already behind.

The new test bears little resemblance to the owners and directors tests previously run by the Premier League and EFL.

It is tougher, wider in reach and, crucially, ongoing. Under the old system, the Premier League, EFL and National League each set their own criteria and largely assessed individuals only at the point of takeover or appointment. After approval, scrutiny faded. The collapses at Derby County, Bury, Reading and Macclesfield exposed how poorly that fragmented, self-regulated model coped when an owner’s circumstances deteriorated.

The ODSE test targets two groups. Owners include anyone with more than 25% of a club’s shares or voting rights, as well as anyone exercising significant influence or control, including indirectly through companies or trusts. Senior managers are those performing one of six defined Senior Management Functions (SMFs).

Crucially, the regime follows function rather than job title. A chair is SMF1, a chief executive SMF2 and a chief financial officer SMF3. Less obvious roles matter too: a head of football operations running most internal operations could be SMF4, a board-level head coach SMF5, and a sporting director with executive authority over regulated activities a plausible SMF6.

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