Draft State of the Game report consultation
Who we are
We are the Independent Football Regulator (the IFR), as established by the Football Governance Act 2025 (the Act). The Act received Royal Assent on 21 July 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
What we are inviting submissions on
Section 10 of the Football Governance Act 2025 requires us to prepare and publish a “State of the Game” report (“the report”). The report must include:
- an overview of the main issues the IFR considers to be affecting English football,
- an assessment of whether any feature or combination of features of English football jeopardises or risks jeopardising the IFR’s ability to advance one or more of its core statutory objectives, and
- information about any matters relating to the state of English football so far as relevant to the exercise of the IFR’s functions under the Act.
The report sets out our understanding of the financial issues in the game including the economics of the market, the underlying incentives, and the drivers of behaviour. It also sets out our findings on non-financial issues such as fan engagement, corporate governance and EDI. Although the IFR’s scope focuses on the top five English men’s leagues, these clubs and leagues are affected by the wider football ecosystem and other economic and societal factors. The report sets out our understanding of these issues and provides the evidence underpinning our provisional views.
The IFR has now published its draft State of the Game Report. We are consulting on this draft.
Following this consultation, we will fully consider all responses and, where appropriate, incorporate these into the final State of the Game report which we must publish before 24 May 2027.How to respond
The draft State of the Game report 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. You are welcome to submit your views on any aspect of the draft State of the Game report and you can upload a written submission if you would prefer. We welcome your views on the questions we set out in the survey, in particular.
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 Tuesday 8 December, at 5pm.
Following this consultation we will consider the responses and, where appropriate, incorporate these into the final State of the Game report.
Confidentiality
Please be aware that, for the purposes of transparency, the IFR intends to publish responses to the draft State of the Game report on its website in due course. If your response contains commercially sensitive or confidential information, you must identify this when submitting your response.
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.
