Second Licensing Regime 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 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. These clubs will have licence requirements in relation to financial regulation, fan engagement, corporate governance and non-financial resources.

In October 2025, the IFR launched the first consultation on the design and operation of the licensing regime, including how the IFR will carry out some of its key responsibilities.

What we are consulting on now 

The IFR has considered the responses to the first consultation and has developed a detailed proposed licensing framework, informed by those responses. The IFR is now consulting on that framework, which includes:

To get clubs onto a provisional licence:

Provisional Licensing Guidance, which provides specific guidance on the provisional licence application and assessment process.

An indicative provisional licence application form, attached as an annex to the Provisional Licence Guidance.

A strategic business plan forecasting template that clubs will be required to complete as part of their application.

Once clubs are licensed:

Licensing Guidance on all parts of the licensing regime, including financial regulation, non-financial resources, corporate governance, fan engagement, annual declarations, discretionary licence conditions, and clubs’ duty not to change their crest, home colours or name without approval.

An example of the standard Licence and Mandatory Licence Conditions (MLCs) document is attached for consultation as an annex to the Guidance.

A non-exhaustive list of example discretionary licence conditions is also attached as an annex. We are not consulting on these example DLCs. They are included as indicative examples to help stakeholders understand the regime. They will not form part of the final Licensing Guidance.

Two reporting templates are also attached as an annex to the Guidance: The annual declaration form and Corporate governance statement guidelines

The IFR’s Football Club Corporate Governance Code (The Club Code). Licensed clubs must produce a statement explaining how they apply The Club Code as part of their MLCs.

Licensing Rules that supplement the Licence and MLCs and include requirements relating to the provisional licence application process.

The IFR is also publishing a response to the first consultation, which provides a summary of the feedback received and sets out the IFR’s response to that feedback.

The IFR will consult on a financial plan reporting template in autumn 2026.

How to respond

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

The survey asks a series of questions about the documents referenced above, which can be accessed through links on the right of this page.

The IFR is particularly interested in feedback on the specific drafting of the documents. Respondents are encouraged to note the paragraph number their feedback relates to, to help the IFR analyse and consider responses.

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 5 May 2026. 

Following this, the IFR will consider the responses and intends to publish the final licensing rules and guidance by 1 July 2026.

The IFR will also publish a response to the second consultation.

As set out in the Licensing Rules and Licensing Guidance, the IFR intends to license clubs before the 2027/28 season, with the provisional licence approval process conducted during the 2026/27 season. The application window is due to open 1 November 2026 and will run to 26 February 2027.

The IFR will run a pilot scheme for provisional licensing prior to the opening of the application window. All clubs in the top five tiers have been contacted and asked to express their interest by 17 April 2026.

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 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 of respondents 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’ which falls 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. Whilst we may publish data about the number of responses received, we will not disclose the personal information of respondents during this process.