Temporary Appointments and ODSE amendments
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
The IFR has powers to operate a licensing regime and to monitor and enforce compliance with requirements relating to financial regulation, fan engagement and club heritage. The Act also establishes an enhanced Owners, Directors and Senior Executives (ODSE) regime.
The ODSE regime originally gained certain powers over incumbent Owners, Directors and Senior Executives in December 2025, alongside rules and guidance related to the regime. It expects to take on powers in relation to prospective owners and Senior Managers, as well as incumbents from May 2026.
What we consulted on
The IFR consulted on a number of changes and additions to the ODSE regime. These proposals include:
A temporary appointments provision for Senior Management Functions where there is an unforeseen absence
Certain technical and clarificatory amendments to other parts of the ODSE regime.
The proposals were set out in the following document:
Consultation Paper CP1/26, which explains the proposals and the rationale for them and contains the following appendices:
Draft ODSE Rules, which set out the new and amended rules that the IFR proposes will apply to clubs, owners, Senior Managers and others engaging with the ODSE regime.
Draft ODSE Guidance, which explains how the regime will operate in practice and what those stakeholders can expect from the IFR
Draft forms for notifying and seeking approval for temporary appointments to cover unforeseen absences
Draft application forms for seeking the IFR approval of proposed new owners and senior managers
The IFR is consulting on these proposals under section 12 of the Act.
Consultation Period
The consultation ran from 17 March 2026 and closed on 10 April 2026.
Accessibility
If you have accessibility requirements relating to our documentation, please get in touch via the Accessibility Requirements page to inform us of your requirements.
Next Steps
The IFR published its consultation response and associated final rules and guidance, and related forms on Friday 1 May 2026.
Compliance with government consultation principles
In preparing this consultation, the IFR took 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.
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.
