Licensing Regime

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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

This first licensing consultation paper sets out how the IFR proposes to establish the licensing regime, as set out in Part 3, and Schedules 4, 5, and 6 of the Act.

The IFR is consulting on these proposals in line with Section 12 of the Act.

Section 12(1-2) of the Act requires the IFR to produce guidance (and therefore consult) on the exercise of its discretionary licence conditions (DLCs) including a statement of the outcomes the IFR seeks to achieve through their use. This consultation sets out the IFR’s initial thoughts and proposals in relation to DLCs. Further consultation on DLCs, including on draft guidance, will take place as part of the second licensing consultation.

The Government will define in regulations those competitions the Act applies to. Clubs playing in those competitions will be within the scope of the regime. Whilst the IFR will only regulate clubs covered by those regulations, this consultation may still be of interest to clubs which fall outside them, as there is a prospect that they may be promoted into a specified competition (and therefore subject to the requirements).

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 8th of December.

Following this first consultation, the IFR will consider the responses and then consult further on draft rules to give effect to the regime. This will include guidance explaining key elements of the regime, application forms, and details of the mandatory licence conditions.

The second consultation is planned for spring 2026. We expect the final rules and guidance on the licensing regime to be published in summer 2026.

As set out in this consultation, the IFR is currently working towards licensing clubs ahead of the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season.

The IFR will publish a response to both licensing consultations.

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

This first licensing consultation paper sets out how the IFR proposes to establish the licensing regime, as set out in Part 3, and Schedules 4, 5, and 6 of the Act.

The IFR is consulting on these proposals in line with Section 12 of the Act.

Section 12(1-2) of the Act requires the IFR to produce guidance (and therefore consult) on the exercise of its discretionary licence conditions (DLCs) including a statement of the outcomes the IFR seeks to achieve through their use. This consultation sets out the IFR’s initial thoughts and proposals in relation to DLCs. Further consultation on DLCs, including on draft guidance, will take place as part of the second licensing consultation.

The Government will define in regulations those competitions the Act applies to. Clubs playing in those competitions will be within the scope of the regime. Whilst the IFR will only regulate clubs covered by those regulations, this consultation may still be of interest to clubs which fall outside them, as there is a prospect that they may be promoted into a specified competition (and therefore subject to the requirements).

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 8th of December.

Following this first consultation, the IFR will consider the responses and then consult further on draft rules to give effect to the regime. This will include guidance explaining key elements of the regime, application forms, and details of the mandatory licence conditions.

The second consultation is planned for spring 2026. We expect the final rules and guidance on the licensing regime to be published in summer 2026.

As set out in this consultation, the IFR is currently working towards licensing clubs ahead of the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season.

The IFR will publish a response to both licensing consultations.

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.

  • Licensing Regime 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.

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Page published: 13 Oct 2025, 09:03 AM