After much back and forth, the Football Governance Act 2025 (the Act) received Royal Assent and came into force on 21 July 2025. 

This landmark legislation introduces the Independent Football Regulator (IFR) as well as a new licensing regime for the top five tiers of men’s English football (Premier League, Championship, League One, League Two and National League), with the aim of promoting sustainability and safeguarding the interests of fans and local communities. The Act currently does not apply to women’s English football – though the Secretary of State retains discretion over future expansion.

The introduction of this Act was to address who will oversee the financial stability of clubs, ensuring that they are run in a manner which promotes their long-term viability, following the collapse of football clubs such as Bury FC (formerly a tier 4 team) and Macclesfield FC (formerly in the National League – 5^th tier team).

Independent Football Regulator

To address this issue, the Act established the IFR, which is the body responsible for overseeing and monitoring clubs to ensure proper governance and compliance with the Act – including the administration of operating licences (see below). 

The IFR’s main objectives are:

1. to protect and promote the financial soundness of regulated clubs;
2. to protect and promote the financial resilience of English football; and 
3. to safeguard the heritage of English football.

The IFR has wide-ranging investigatory and enforcement powers. It may request information from clubs where there are reasonable grounds to suspect a breach of the Act. During investigations, warrants may be issued allowing IFR officers to enter and search club premises. Outcomes of such investigations may include injunctions to halt specific activities, financial penalties, suspension or revocation of operating licences, or the appointment of a skilled person to assist the club. It is therefore essential that clubs protect themselves by ensuring full compliance with the Act.  

The IFR is currently being established and is expected to be completed in the autumn. The office for the incoming IFR has started to set out plans for how it intends to implement measures relating to the owners and directors test to protect clubs and fans from unsuitable ownership and leaders. 

New operating licensing regime 

In order to operate a football club and compete in the top 5 tiers, clubs are required to obtain one of the following licences: 

1. Provisional Licence: or 
2. Full Licence. 

Both licences enable a club to play in major competitions, leagues and matches. Clubs must first apply for a Provisional Licence before progressing to a Full Licence.

A Provisional Licence is the first step for all clubs. To apply for a Provisional Licence, clubs must satisfy the mandatory licence conditions which are set out in the Act. Clubs will also have to submit a business plan containing (among other things) financial information, a personnel statement listing club owners, officers, senior managers, and stating that they have carried out fan consultations. 

Once the IFR is satisfied that the club complies/will comply with the required duties, it will grant a Provisional Licence which will be valid for three years.  The IFR will have the power to impose ‘Discretionary Licence Conditions’ where it believes it is necessary to do so. Once the Provisional Licence is granted, the IFR will monitor the club’s compliance with the relevant criteria. If satisfied, the IFR will grant a Full Licence. If the criteria are not met, the three-year Provisional Licence period may be extended, but sanctions could be imposed. 

Once granted, a Full Licence allows clubs to operate indefinitely – without expiration or a need for renewal. However, the IFR will continue to monitor clubs with a Full Licence and may at any time impose Discretionary Licence Conditions if it feels that the club is no longer meeting the threshold requirements.

Fan engagement

The Act has a focus on fan engagement and the protection of fans, introducing a ‘fan engagement threshold requirement’ aimed at protecting club heritage. Here, clubs will need to consult with fans and consider their views on ‘relevant matters’ such as proposed changes to the club’s name, home grounds, shirt colours, emblems/crests, future strategy or ticket prices. This ensures that fans have a real say in preserving the identity and legacy of their club. Meeting this threshold is a prerequisite for obtaining a Full Licence.  

Suitability of club owners and officers

The suitability of the club’s owners or officers will be closely monitored to ensure that clubs are run by individuals who are sufficiently capable. The ‘fitness criteria’ include requirements of honesty, integrity and financial soundness. If the IFR determines that an owner or officer is not suitable to hold their role, they will be removed.  

How can Anthony Collins help

Clubs in the top five tiers of men’s football, and those aspiring to reach them, should take steps to ensure compliance with the Act. The IFR has significant powers aimed at protecting the sport. Clubs can protect themselves by understanding their requirements under the Act and working towards securing a Provisional Licence as early as possible. Doing so will not only provide clarity and certainty but also promote and empower the fans and local communities who are at the heart of every club. 

At Anthony Collins, we understand the unique challenges faced by local football clubs looking to climb up the tier rankings and having to navigate the new regulatory landscape introduced by the Football Governance Act 2025. Our team of legal experts are well-equipped to provide tailored advice on governance arrangements, licensing compliance, and stakeholder engagement. Whether you are seeking support with IFR licensing requirements, enhancing your governance structures, or ensuring meaningful fan consultation, we are here to help clubs build resilience and thrive under the new regime. 

For more information

If you would like more information or have any questions about the Football Governance Act 2025, please contact Rumandeep Dhariwal or David Alcock.