State of the Game report Terms of Reference
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 and 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
We 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.
We 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.
In order to best implement these powers, prioritise within the regime and take regulatory decisions, we need to develop a deep and comprehensive understanding of how the football industry works.
What we are inviting suggestions on
Section 10 of the Football Governance Act 2025 requires us to prepare and publish a “State of the Game” report (“the report”) on the state of English football so far as relevant to the exercise of our functions. Prior to this, we must publish a notice stating our intention to prepare a report and inviting suggestions as to matters to be included. These Terms of Reference fulfil this function. Prior to publishing the report, we must also prepare and consult on a draft final report.
The report will capture our understanding of the economics of the market, the underlying incentives, and the drivers of behaviour. Although the IFR’s scope will focus 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, which the report will set out our understanding of. The report will focus on issues relating to the Football Governance Act 2025, including financial sustainability and club heritage. Topics such as ticket prices and Video Assistant Referees (VAR) are outside this scope.
How to respond
The proposed Terms of Reference for the State of the Game report can be accessed here or via the link to the right of this page under 'Document'.
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 Tuesday 17th of February 5pm.
Following this consultation we will consider the responses and, where appropriate, incorporate these into the draft State of the Game report.
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.
