Frequently asked questions

Set out below are answers to questions likely to be frequently asked in connection with the IFR’s powers to assess the suitability of club owners. These reflect RamsTrust’s interpretation and understanding of the regulations to the best of our knowledge. They provide a summary rather than coverage of every specific element of the rules and guidance in this area and focus on the approach relating to individuals rather than organisations, although the principles applied to owners and prospective owners that are not natural persons are essentially the same.

Who does the IFR’s owner suitability regime apply to?

It applies to the owners of regulated clubs – essentially every club operating a team in the top five levels of men’s football in England. The ownership qualifying conditions include holding, directly or indirectly, more than 25% of the shares or voting rights in the club. This means there can be more than one owner, but that (say) American celebrities taking small minority stakes in English clubs may not qualify as owners in this context, unless they have a right to:
– exercise, or do actually exercise, significant influence or control over club activities; and/or
– appoint or remove an officer (director, senior executive or senior manager) of a club.

What is “significant influence or control”?

“Significant influence or control” has been defined by the Secretary of State for Culture, Media and Sport as being “where a person has absolute decision or veto rights over key decisions related to the running of the club’s business”. Such decisions may include:
– Adopting or amending material aspects of a club’s financial plan e.g. to the transfer budget
– Commercial decisions e.g. adopting new sponsors
– Determining how the club votes at competition organisers’ meetings
– The sale of key assets such as players or the training ground.

What does the suitability assessment process look like?

Regulated clubs (or a prospective owner) are required to notify the IFR when there is a “reasonable prospect” of a person becoming an owner of the club. The prospective owner has to be identified and the reasons why there is a reasonable prospect of them becoming an owner explained, including the ownership conditions likely to be met. An application must then be submitted to the IFR. Only when the regulator has confirmed the application is complete, will the suitability assessment commence.
Not until the IFR determines them to be suitable can a person become an owner of a regulated club, with the IFR having 90 days from receipt of the complete application to make its determination, extended to 150 days in exceptional circumstances.

What are the areas covered by the suitability assessment?

The IFR approves a new owner when it:
– Considers the prospective owner meets the owner fitness criteria of having the requisite honesty and integrity and of being financially sound
– Considers the prospective owner has sufficient financial resources
– Does not have grounds to suspect the prospective owner has any source of wealth connected to serious criminal conduct.

What information does the IFR require to conduct its assessment?

To ensure consistency and that the right information is provided the IFR has produced a prescribed application form. An application that does not use the form will not be accepted. Key information disclosure requirements for each area of the suitability assessment include the following.

Honesty and integrity
– The individual’s criminal convictions and proceedings to which they have been subject and conduct abroad that would amount to a serious offence if it had occurred in England or Wales*
– Non-criminal court or tribunal proceedings to which the individual has been a party or regulatory action taken in relation to the prospective owner e.g. being disqualified as a company director*
– Whether they have been implicated in disciplinary action by a sports body, failed to comply with requirements set by such an organisation or been implicated in misleading or not being open and cooperative with the IFR, a competition organiser or other regulator*
– Whether the applicant is prohibited from entering the UK or is subject to UK sanctions arising from money laundering activity

Financial soundness
Not the same as sufficiency of financial resources but relating to the prospective owner’s direct experience of bankruptcy and similar arrangements in connection with insolvency, in both the UK and elsewhere.*
*These will not automatically disqualify a prospective owner. The IFR will take account of such factors as the number of instances, their seriousness and nature, the time since they occurred and their relevance to football club governance.

Sufficient financial resources
The IFR will judge sufficiency based on the circumstances of the club involved, with consideration of:
– Its current and likely future circumstances
– The intentions for it of the prospective owner, supported by commitments and evidence that they will be able to provide the funds needed to operate according to the financial plan and their ability and willingness to provide additional support should the club experience financial difficulties

The prospective owner is required to disclose their strategy for the club for a minimum of three years, linked to a financial plan for the same period. The prospective owner will be required to provide proof of funds and the IFR has powers to seek information directly from third parties, such as banks. These powers to request information and explanations beyond the mandatory requirements, in order to properly assess an application, have legislative backing under the Football Governance Act 2025 (FGA25).

Source of wealth
Prospective owners must explain and evidence their source of wealth, with the IFR again able to request information from third parties, including law enforcement and other regulatory agencies. The IFR will then consider if there are grounds to suspect that a prospective owner’s sources of wealth have any connections to serious criminal conduct perpetrated anywhere in the world.

Will the IFR assess the suitability of incumbent owners?

Only in defined circumstances! Owners in place when the IFR’s powers in this regard became effective and when their club becomes a regulated club, as well as owners previously approved by the IFR, will not be assessed for suitability unless the IFR receives compelling information (not rumour and media speculation) that gives it grounds:
– For concern about whether an owner meets the individual fitness criteria, including financial soundness; or

– To suspect that the owner has a source of wealth connected to serious criminal conduct

The IFR does not have the power to determine whether an incumbent owner has sufficient financial resources, as required for prospective owners. However, RamsTrust assumes this will be subject to on-going assessment through the mandatory licence condition regarding financial planning and the full licence requirement for clubs to be able to show appropriate financial resources.

What action can the IFR take when an owner is deemed unsuitable?

When the IFR determines that an owner is unsuitable it is required to direct that person to take all reasonable steps to cease to be an owner within a specified period. Should the owner fail to comply with such a direction the IFR has the power to suspend or revoke the club’s license, preventing it from operating a team in the top five levels of men’s football in England.

Will the IFR’s approach to owner suitability be more effective than those of the leagues?

The approach of the IFR is very similar to those of the EFL and Premier League in this regard. However, the IFR has committed to a more rigorous approach which will be supported by:
– Statutory backing for its powers, reinforced by FGA25 provisions that criminalise submission to the IFR – knowingly or recklessly – of false or misleading information
– A more structured and defined approach to information gathering, with more focus on detailed evidence rather than reliance on self declaration
– The IFR’s core (in fact only) responsibility being that of regulation – unlike the leagues with their wider range of responsibilities as competition organisers for example

We understand the EFL intends to terminate its suitability testing role once the IFR’s club licensing regime is fully activated (from the 2027/28 season), but that the Premier League plans to retain theirs – an indication perhaps of the respective attitudes of these two bodies towards the IFR and FGA25.