The Independent Football Regulator (IFR) is now operational under the Football Governance Act 2025.

The IFR has been conducting a series of consultations to shape the detail of how the licensing regime will operate in practice. The second of these consultations closed on 5 May and the final licensing guidance is due to be published by 1 July.

Clubs will then have some time to get to grips with the guidance before the IFR’s licensing regime opens formally on 1 November 2026. As a reminder, clubs operating in the Premier League, EFL Championship, League One, League Two, and National League will be required to hold a licence to participate in their competition.

The question for most clubs now is not whether to engage with the regime, but how to navigate it effectively as the key milestones approach, working with their liaison officers at the IFR to ensure they obtain their licences in a timely manner.

Why Bates Wells

At Bates Wells, we have been close to this legislation from its earliest days. We acted as legal advisers to Fair Game, the fan-led coalition that campaigned persistently and effectively for meaningful reform of English football’s governance, and we worked alongside them throughout the Bill’s Parliamentary passage. As we have written previously, Bates Wells and Fair Game together drove a number of key improvements to what is now the Football Governance Act, from strengthening fan engagement duties to sharpening the financial resilience requirements that sit at the heart of the regime.

We have also advised Kick It Out on its responses to the IFR’s consultations, engaging with the IFR to encourage it to take EDI seriously.

That means we come to this work with something that not many advisers can offer: a genuine, detailed understanding of why the legislation is drafted the way it is, what Parliament intended, and how the IFR is likely to interpret its mandate. We were not reading the legislation from the outside — we were helping to shape it.

But our position is not only about our history regarding the Act. Bates Wells has deep expertise across the full range of disciplines that the licensing regime will engage:

  • Corporate and governance advice, including reviewing board structures, ownership arrangements, and compliance frameworks against the IFR’s requirements
  • Charity and purpose-driven organisations, where our longstanding expertise in advising mission-led organisations gives us a natural affinity with the community and fan engagement dimensions of the new regime
  • Employment and regulatory matters, relevant to the IFR’s expectations around how clubs treat their people and their communities
  • Commercial and contract work, where clubs will need advice on how the regime interacts with existing arrangements, sponsorship structures, and commercial agreements

Whether a club needs a comprehensive audit of its readiness for licensing, advice on a specific aspect of the regime, or support in engaging with the IFR or the appeals process, we are well placed to help.

Join us for our webinar this July

We recognise that for many clubs — particularly those outside the top flight — the licensing regime may feel complex and, at times, overwhelming. Our aim is to make it accessible.

To that end, Bates Wells will be hosting a webinar in July at which our team will walk through the key features of the regime, the practical steps clubs should be taking now, and what the IFR’s consultations mean for the road ahead. We will also be taking questions, so it will be an opportunity to raise the issues most relevant to your club’s specific circumstances.

Details will be confirmed shortly — keep an eye on our website and social media channels for the date and registration link.

In the meantime, if you have questions about the IFR, the licensing regime, or how Bates Wells can support your club, please do not hesitate to get in touch with our team. This is a significant moment for English football, and we are ready to help clubs navigate it.

The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice upon which you should rely. In particular, the information should not be used as a substitute for a full and proper consultation with a suitably qualified professional. Please do contact the Bates Wells team if you require further advice.