Internal Review Function

Share Internal Review Function on Facebook Share Internal Review Function on Twitter Share Internal Review Function on Linkedin Email Internal Review Function link

Who we are

The Football Governance Act 2025 (the Act) received Royal Assent on 21 July, 2025. The Act establishes the Independent Football Regulator (the IFR).

The IFR’s core statutory objectives are to:

  • protect and promote the financial soundness of regulated clubs

  • protect and promote financial resilience of English football

  • safeguard the heritage of English football

The IFR will have powers to operate a licensing regime, and to monitor and enforce compliance with requirements on financial regulation; fan engagement; club heritage; and will introduce an enhanced club owners, directors and senior executives test.

The IFR will set corporate governance standards, will oversee a number of obligations on clubs protecting club heritage, e.g. stadia sales, changes to badges and kit colours, and will have the power to prohibit regulated clubs from joining competitions where they are not fair and meritocratic, and would threaten the heritage and sustainability of English football.

Establishing the IFR is expected to be complete in the autumn, when the organisation will have an independent Board (comprising Executive and Non-executive Directors, a Chair and a Chief Executive Officer).

What we are consulting on

The Act provides directly affected parties (for example - clubs, owners, senior executives) with the ability to request an internal review of certain IFR decisions, referred to as ”Reviewable Decisions”, from a panel of decision-makers who were not involved in the original decision. The list of Reviewable Decisions covers a wide range of operational and enforcement related decisions across the IFR’s regime, varying in their nature and their implications for the person subject to the decision.

The IFR is consulting on a draft procedural framework which sets out how the internal review function will operate. The IFR’s intention is that the proposed procedural framework will provide a quick and less costly alternative for persons seeking to challenge a decision of the IFR.

The IFR is in tandem consulting on draft Costs Rules which set out the IFR’s approach to recovering costs in cases where the internal reviewer upholds the IFR’s Reviewable Decision, following the conclusion of an internal review.

How to respond

The consolidated consultation document can be accessed here or via the link to the right of this page under 'Documents'.

You can submit your response to the proposals by filling out the survey below.

Accessibility

If you have accessibility requirements relating to our consultation documentation, please get in touch via the Accessibility Requirements page to inform us of your requirements.

Next Steps

This consultation will close on Monday 10th of November. We will consider the responses we receive to inform our next steps.

Compliance with government consultation principles

In preparing this consultation, the IFR has taken into account the published government consultation principles, which set out the principles that government departments and other public bodies should adopt when consulting with stakeholders.

Confidentiality

We do not intend to publish any individual responses. Information contained in responses may be used or summarised in public documents.  If your response contains sensitive information, please identify it and explain why you consider it sensitive.

Personal Data

We accept the right for responses to remain anonymous and a response that wishes to remain confidential should be appropriately marked. We may contact an individual to discuss their request for confidentiality further and ask for reasons.

We are subject to the rules set out in the Freedom of Information Act (FOIA), the Data Protection Act (DPA) and the Environmental Information Regulations (EIR).

Section 1 of FOIA gives a general right of access to information held by public authorities, and the Act adds the IFR to the list of ‘public bodies’ which fall within the remit of FOIA.

The EIR requires public authorities to make available on request the environmental information they hold.

EIR (reg. 2(2)) defines “public authority” by direct reference to FOIA. Personal data collected as part of the consultation process will fall within the remit of the DPA.

Section 7(1)(a) defines “public authority” by direct reference to FOIA. Whilst we may publish data about the number of responses we receive, it must not disclose the personal information of any of the respondents during this process.

Who we are

The Football Governance Act 2025 (the Act) received Royal Assent on 21 July, 2025. The Act establishes the Independent Football Regulator (the IFR).

The IFR’s core statutory objectives are to:

  • protect and promote the financial soundness of regulated clubs

  • protect and promote financial resilience of English football

  • safeguard the heritage of English football

The IFR will have powers to operate a licensing regime, and to monitor and enforce compliance with requirements on financial regulation; fan engagement; club heritage; and will introduce an enhanced club owners, directors and senior executives test.

The IFR will set corporate governance standards, will oversee a number of obligations on clubs protecting club heritage, e.g. stadia sales, changes to badges and kit colours, and will have the power to prohibit regulated clubs from joining competitions where they are not fair and meritocratic, and would threaten the heritage and sustainability of English football.

Establishing the IFR is expected to be complete in the autumn, when the organisation will have an independent Board (comprising Executive and Non-executive Directors, a Chair and a Chief Executive Officer).

What we are consulting on

The Act provides directly affected parties (for example - clubs, owners, senior executives) with the ability to request an internal review of certain IFR decisions, referred to as ”Reviewable Decisions”, from a panel of decision-makers who were not involved in the original decision. The list of Reviewable Decisions covers a wide range of operational and enforcement related decisions across the IFR’s regime, varying in their nature and their implications for the person subject to the decision.

The IFR is consulting on a draft procedural framework which sets out how the internal review function will operate. The IFR’s intention is that the proposed procedural framework will provide a quick and less costly alternative for persons seeking to challenge a decision of the IFR.

The IFR is in tandem consulting on draft Costs Rules which set out the IFR’s approach to recovering costs in cases where the internal reviewer upholds the IFR’s Reviewable Decision, following the conclusion of an internal review.

How to respond

The consolidated consultation document can be accessed here or via the link to the right of this page under 'Documents'.

You can submit your response to the proposals by filling out the survey below.

Accessibility

If you have accessibility requirements relating to our consultation documentation, please get in touch via the Accessibility Requirements page to inform us of your requirements.

Next Steps

This consultation will close on Monday 10th of November. We will consider the responses we receive to inform our next steps.

Compliance with government consultation principles

In preparing this consultation, the IFR has taken into account the published government consultation principles, which set out the principles that government departments and other public bodies should adopt when consulting with stakeholders.

Confidentiality

We do not intend to publish any individual responses. Information contained in responses may be used or summarised in public documents.  If your response contains sensitive information, please identify it and explain why you consider it sensitive.

Personal Data

We accept the right for responses to remain anonymous and a response that wishes to remain confidential should be appropriately marked. We may contact an individual to discuss their request for confidentiality further and ask for reasons.

We are subject to the rules set out in the Freedom of Information Act (FOIA), the Data Protection Act (DPA) and the Environmental Information Regulations (EIR).

Section 1 of FOIA gives a general right of access to information held by public authorities, and the Act adds the IFR to the list of ‘public bodies’ which fall within the remit of FOIA.

The EIR requires public authorities to make available on request the environmental information they hold.

EIR (reg. 2(2)) defines “public authority” by direct reference to FOIA. Personal data collected as part of the consultation process will fall within the remit of the DPA.

Section 7(1)(a) defines “public authority” by direct reference to FOIA. Whilst we may publish data about the number of responses we receive, it must not disclose the personal information of any of the respondents during this process.

  • Internal Review Function Questions

    Before completing these questions please take some time to review the consultation document here as the questions will reference this. 

    You will be able to return to a previous page at any point during the survey by clicking the 'previous' button, and if you need to close and complete any of the questions later, you will be able to do this by logging back in.

    Once you have submitted your responses you will be unable to edit them.

    Take Part
    Share Internal Review Function Questions on Facebook Share Internal Review Function Questions on Twitter Share Internal Review Function Questions on Linkedin Email Internal Review Function Questions link
Page published: 13 Oct 2025, 08:58 AM