Liquidity and Licensing Technical Consultation
Who we are
We are the Independent Football Regulator (IFR), as established by the Football Governance Act 2025 (the Act). The Act received Royal Assent on 21 July 2025 and the IFR was legally established on 1 November 2025.
The IFR’s core statutory objectives are to:
protect and promote the financial soundness of regulated clubs
protect and promote the financial resilience of English football
safeguard the heritage of English football
In line with this, the IFR will operate a licensing regime for clubs in the top five tiers of English men’s football. Clubs will need a licence to operate, and must meet requirements on finances, fan engagement, governance and their overall resources.
To obtain and maintain a full licence, clubs will need to meet three Threshold Requirements including a requirement to hold and maintain appropriate financial resources. From May 2028, clubs will be required to submit a financial plan annually to support the IFR’s assessment of whether this requirement is met.What we are consulting on
This consultation covers three discrete areas that relate to the IFR’s broader Licensing process.
Chapter One sets out the IFR’s proposed risk-based approach to liquidity, including how a club’s risk profile will inform its liquidity expectation and how individual circumstances will be taken into account.
This should be read alongside the IFR’s Supervisory Strategy, published 10 November 2026, which sets out the IFR’s wider approach to supervision, including how it will identify and respond to financial risk.
Chapter Two seeks views on the reporting template for the financial plan Mandatory Licence Condition (‘MLC’), which clubs are required to submit annually once on a provisional licence (i.e. from May 2028). The IFR will use this to assess whether a club is meeting the appropriate financial resources Threshold Requirement.
This should be read alongside the financial plan template.
Chapter Three seeks views on proposals for introducing a provision to allow the IFR to transfer a licence between legal entities within a club’s structure.
This should be read alongside Annex A of this consultation.
How to respond
The 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.
Next Steps
This consultation will close on 18th December 2026.
Following consultation, the relevant sections of the IFR’s Supervisory Strategy and Licensing Rules and Guidance will be updated.
Compliance with government consultation principles
In preparing this consultation, the IFR has taken into account the published government consultation principles, which set out how government departments and other public bodies should consult with stakeholders.
Confidentiality
We do not intend to publish any individual responses. Information contained in responses may be used or summarised in public documents.
Personal Data
We accept respondents’ right to remain anonymous, and responses that are confidential should be clearly 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’ that fall within the remit of FOIA.
The EIR requires public authorities to make environmental information available on request.
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. While we may publish data about the number of responses received, we will not disclose the personal information of respondents during this process.
