Football Governance Act becomes law as clubs urged to note obligations and implications

David Thorneloe, public law and legislation specialist at Pinsent Masons, was commenting ahead of the Act obtaining royal assent, which is expected within days.

The Football Governance Act 2025, which establishes an Independent Football Regulator (IFR) and a mandatory licensing regime for clubs in the top five tiers of the men’s game, has passed all its stages of approval in parliament, and will soon be enshrined in law, marking a new era of statutory regulation for the men’s game in England.

Thorneloe said: “The legislation marks a fundamental shift in how English football is governed. It is therefore vital for clubs to familiarise themselves with the requirements and potential implications of the legislation, which will operate in tandem with the existing requirements set by the leagues. Early engagement with the IFR and the leagues will help ensure the system is shaped to minimise duplication and work well for everyone.”

The legislation represents the culmination of work that began with the fan-led review of football governance in 2021, chaired by former sports minister Tracey Crouch. The review was launched in response to growing concerns over financial management, club collapses, and the threat of breakaway competitions like the European Super League.

The new IFR will be tasked with overseeing the financial health, governance, and integrity of clubs across the top five tiers of the English men’s game – from the Premier League down the National League. It is the first time that the sport will be subject to statutory regulation, with a dedicated body focused on long-term sustainability and interests of fans.

The legislation also introduces a licensing regime for clubs, requiring them to meet strict criteria on financial stability, ownership transparency, and fan engagement. Under the Act, clubs will need to disclose their ultimate beneficial owners, provide detailed financial plans, and demonstrate how they intend to fund operations stably.

The IFR will also have powers to block unsuitable owners, revoke licences, and – in extreme cases- force changes in club ownership. It will be responsible for safeguarding club heritage, including names, badges, and stadiums, and will have the authority to prevent participation in “prohibited competitions” that do not need standards of merit-based qualification and open competition – a direct response to the European Super League threat.

The IFR will publish a “state of the game” report within 18 months of the Act’s passage, and every five years thereafter. This report will assess the health of English football and identify systemic risks.

Thorneloe said the passing of the Act will increase pressure on the Premier League and English Football League to reach an agreement on redistributing a portion of Premier League broadcast revenue to the lower leagues. If they remain unable to break the longstanding deadlock by the end of the 2025-26 season, then either league may be able to trigger the ‘backstop’ process in the Act, which will allow the IFR to mediate, arbitrate and ultimately impose a new agreement.

While the Act provides the legal framework, much of the detail will be developed through secondary rules and guidance issued by the IFR. The regulator is expected to begin a wide-ranging consultation process this autumn, engaging with clubs, leagues, fans, and other stakeholders to shape the new regime. The development process is likely to last up to 12 months, with the majority of new rules expected to come into force ahead of the 2026-27 season. However, the exact timeline remains to be confirmed.