The Football Governance Act 2025 marks the most significant overhaul of English football’s structure since the Premier League’s creation in 1992.
According to Argus Pro, with the Independent Football Regulator (IFR) now holding powers over licensing, financial scrutiny, ongoing supervision and the removal of unsuitable owners, clubs that have never operated under statutory oversight are entering unfamiliar ground.
The challenge has a clear precedent. After the 2008 crisis, the UK financial sector went through a similar transformation. The Financial Services Act 2012 split oversight between the Financial Conduct Authority (FCA), responsible for conduct, and the Prudential Regulation Authority (PRA), which handles systemic risk. Both moved to continuous, risk-based supervision. Firms that adapted quickly were rewarded, while those that approached regulation as a paperwork exercise paid heavily.
Under the new Act, 116 clubs across the top five men’s tiers face statutory regulation, most for the first time. The IFR can grant, amend and revoke operating licences, demand financial plans and governance statements, investigate breaches, impose penalties and block the sale or relocation of key assets. At the centre sits the Owners, Directors and Senior Executives (ODSE) regime, consulted on in September 2025, under which suitability can be reassessed at any time.
Six lessons from financial services stand out. First, regulators work through relationships. Firms that disclose problems early are treated very differently from those whose failings are discovered. Second, documentation underpins credibility, as sound but undocumented decisions offer the regulator little basis for confidence. Third, culture forms the real control environment, with tone from the chair, chief executive and owner shaping outcomes more than any written policy.
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