Westminster Media Forum

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Next steps for football governance in England

IFR powers & supervision | provisional licensing & club readiness | State of the Game priorities | financial sustainability & accountability | sponsorship & structural pressures | proportionality & regulatory burden | revenue distribution & backstop powers | owner & officer suitability | financial plans & reporting | supporter engagement & club heritage

Morning, Wednesday, 18th November 2026

Online


This conference will examine next steps for football governance in England as the statutory regime under the Football Governance Act 2025 moves from design into operation.


The agenda will consider implementation of the Independent Football Regulator’s licensing and supervisory framework including measures relating to ownership, corporate governance and accountability, and questions of proportionality and interaction with existing football rules. Further sessions look at financial sustainability and revenue distribution across the football pyramid, and the future for supporter engagement and protection of club heritage.


With the provisional licence application window opening in November, it will bring together stakeholders with policymakers to discuss the early experience and practical aspects of entering the new regime. Areas for discussion include requirements for evidence and financial planning, supervisory relationships and implications for clubs with differing resources and circumstances. Sessions will consider priorities for proportionate implementation, including the cumulative regulatory burden, interaction with competition rules, and the transition from provisional to full licensing.


Discussion will also examine how the new statutory arrangements fit with existing governance and regulation across English football, including the respective roles of the IFR, the FA and competition organisers. Attendees will consider approaches to effective coordination and information sharing, avoiding unnecessary duplication or conflicting requirements, and what the next phase of reform means for clubs, investors, supporters and others affected by the regime.


In the context of the State of the Game process, the agenda will bring out latest thinking on financial and structural pressures across the pyramid, looking at club revenues and costs, owner funding, investment, player wages and competitive incentives. Delegates will consider the prospects for future financial arrangements between the Premier League and EFL, assess the potential impact of different approaches to distribution for clubs across the pyramid, as well as the circumstances in which the IFR’s backstop powers might become relevant.


Further discussion will consider implementation of the Owners, Directors and Senior Executives regime and wider priorities for club governance and accountability, including suitability and due diligence, complex ownership structures and safeguards against illicit finance. Sessions will also examine how the emerging framework affects supporter involvement in significant club decisions, corporate governance and protection of club heritage.


Owners, Directors & Senior Executives regime
The agenda will examine early operation of the ODSE regime, including suitability assessments, due diligence and investigatory processes, alongside safeguards against illicit finance and the implications for ownership oversight and club management.


Areas for discussion include:

  • suitability tests: honesty and integrity - financial soundness - competence
  • due diligence: source of wealth and financial resources - evidence requirements and standards for decision-making - timeliness of determinations 
  • ownership structures: complex and layered structures - multi-club and cross-border ownership - influence falling short of formal control
  • illicit finance: safeguards against opaque funding - information sharing with the FCA, law enforcement and other agencies
  • incumbent owners & removal: application to existing owners and officers - grounds for removal and disqualification - consequences for clubs and supporters where an owner is found unsuitable

Club licensing, corporate governance & supporter engagement
As clubs enter the provisional licensing process, the agenda will examine early implementation of the final framework and its implications for financial planning, corporate governance, accountability and supporter engagement across English football.


Areas for discussion include:

  • applications:
    • personnel statements and strategic business plans - early experience of the application process - lessons from the pilot
    • implications of the timetable for determinations by May 2027
  • financial plans: annual financial planning and reporting - stress testing and credible funding - financial plan template and evidence requirements
  • corporate governance: applying the Football Club Corporate Governance Code - board accountability, risk management and annual statements - equality, diversity and inclusion reporting
  • supporter engagement: what counts as meaningful consultation - fan representative structures - consultation on ticket prices, heritage and strategic decisions
  • heritage protections: approvals for dealings in home grounds - changes to crest, colours and name - duties to inform supporters during insolvency

Supervision, enforcement & regulatory cooperation
The operation in practice of the new statutory regime will be examined, including approaches to supervision and enforcement, proportionality and regulatory burden, the cost of regulation, and coordination with football authorities and other bodies.


Areas for discussion include:

  • supervision: club supervisors and relationship management - the IFR's supervisory approach - risk-based scrutiny and information requests
  • investigations & enforcement: information gathering - intervention thresholds - sanctions, reviews and appeals
  • proportionality: tailoring requirements to club size and circumstances - duplication with league rules, including the PL’s squad cost ratio and systemic resilience rules
  • cost of regulation: IFR resourcing and operating costs - the statutory levy on regulated clubs and transition from central funding - transparency over budgets and value for money
  • coordination:
    • IFR-FCA memorandum of understanding - sponsorship and financial promotions directed at supporters
    • cooperation with the FA, competition organisers, law enforcement and public bodies

State of the Game report, financial sustainability & future regulation
Further sessions will draw on the State of the Game process in considering financial sustainability, governance and structural issues across English football, as well as how emerging evidence might inform the IFR’s approach to supervision and future regulation. Delegates will discuss revenue distribution, investment, ownership models and long-term resilience across the football pyramid.


Areas for discussion include:

  • the evidence base: club revenues, costs and balance sheets - owner funding and player wages - academy investment and player trading
  • financial pressures: wage inflation, debt and operating costs - the effects of promotion and relegation on club behaviour - lessons from recent administrations and near-failures
  • revenue distribution:
    • current Premier League-EFL discussions and prospects for agreement - parachute payments, solidarity and competitive balance
    • the position of National League clubs in future distribution
  • the backstop: circumstances in which the power might be triggered - incentives for a negotiated settlement - implications for relationships between competitions
  • future development: how findings and wider evidence might inform licence conditions and supervision - evidence needed to evaluate the regime - priorities for the next phase of reform

All delegates will be able to contribute to the output of the conference, which will be shared with parliamentary, ministerial, departmental and regulatory offices, and more widely. This includes the full proceedings and additional articles submitted by delegates.



Keynote Speaker

Fiona Mackinnon-Miller

Head, Scams, Promotions, Engagement and Perimeter Department, Financial Conduct Authority

Keynote Speakers

Fiona Mackinnon-Miller

Head, Scams, Promotions, Engagement and Perimeter Department, Financial Conduct Authority

Laura Nell

Deputy Director, Policy, Independent Football Regulator