Following our recent webinar on the Independent Football Regulator’s licensing regime, this article summarises the critical points that English men’s football clubs in the top five tiers need to understand and act upon now.
Where we stand
The IFR has completed its second consultation on the licensing regime with no fundamental changes to the proposed framework. All men’s clubs in the top five tiers will need a provisional licence for the 2027/28 season, with the application window opening in November 2026. Clubs should expect to be contacted by their allocated supervisor before November.
The licensing pathway operates in two stages. Provisional licences come first and can last up to three years, acting as a bridge to full licensing. The application window runs from 2 November 2026 to 26 February 2027, with decisions expected by the end of May 2027. Clubs must complete one full round of the four reporting obligations before obtaining a full licence, meaning the earliest possible date for full licensing is June 2028.
The provisional licence application
A provisional licence application must include a personnel statement and a strategic business plan. The personnel statement identifies the club’s owners and officers, the ultimate owner, job titles and roles, and the specified senior management functions performed by senior managers. This must be formally approved and signed, published once accepted, and updated when material changes occur.
The strategic business plan contains information about the proposed operation of the club, estimated costs, funding sources, and financial projections up to 30 June 2028. Clubs must address narrative questions that necessitate preparatory work in areas including due diligence and anti-money laundering, risk management, and fan consultation.
Ongoing obligations
Once a provisional licence is granted, mandatory licence conditions apply immediately. These include submitting and complying with financial plans, providing a corporate governance statement, conducting fan consultation, and submitting an annual declaration on non-financial resources.
Clubs must also comply with additional duties, including not operating in prohibited competitions, not disposing of home grounds without approval, and notifying the IFR of changes in circumstances relevant to its functions.
To obtain a full licence, clubs must meet threshold requirements concerning appropriate financial resources, appropriate non-financial resources, and fan engagement. Compliance with the mandatory licence conditions does not necessarily mean a club meets the threshold requirements, though it may help demonstrate such compliance.
The Corporate Governance Code operates on an “apply and explain” principles-based approach, covering board purpose and strategy, risk oversight and controls, board composition and accountability, equality, diversity and inclusion, and stakeholder relationships and engagement. Again, this may require considerable preparatory work to be undertaken by clubs.
What clubs should do now
- Appoint an IFR lead
- Familiarise yourself with the various guidance documents
- Review the provisional licence application templates and identify gaps in your current position
- Diarise board meetings for application approval and the various reporting deadlines throughout the year
- Implement or review policies and procedures regarding due diligence and anti-money laundering, risk management, fan consultation and decision-making, conflicts of interest, equality, diversity and inclusion, and IFR notifications
- Review board composition against IFR metrics
- Consider whether board governance training is required
How Bates Wells can help
Bates Wells was instrumental in developing the Football Governance Act 2025 and is uniquely positioned to advise clubs on IFR compliance. We can assist with licence readiness, including policies, procedures and training, application preparations, ongoing liaison with supervisors, report preparation, and ongoing compliance advice.
If you would like to discuss your club’s readiness for the IFR licensing regime, Ben Thomas and Helen Fry are offering a free 30-minute call. Contact Ben at [email protected] or 020 7551 7795, or Helen at [email protected] or 020 7551 7650.
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 advice.