Under the Football Governance Act 2025 (the Act) regulated clubs will need a licence to participate in specified competitions.  Clubs will first apply for a provisional licence, before progressing to a full licence up to three years later, allowing them time to adapt to the new requirements.  The provisional licence application process is scheduled to commence in November 2026, with all clubs licensed before the 2027/28 season begins.  This will follow final publication of the IFR’s rules and guidance in the summer of 2026 and a period of familiarisation for clubs.

The IFR has a issued a consultation document setting out proposals for the design and operation of the licensing regime.  This provides a framework for the regime, with further consultation to come in Q1 of 2026 on more detailed rules, guidance, application forms and the mandatory licence conditions.  These conditions must be complied with by clubs once they are on a provisional licence and continue when they are on a full licence.  They comprise conditions related to a club’s:

• Financial plans: Clubs will submit and comply with an annual financial plan
• Approach to corporate governance: The IFR will publish a Football Club Corporate Governance Code.  Clubs will periodically and publicly report on compliance with it
• Approach to fan engagement: Clubs will consult regularly with their supporters on five “relevant matters” (see below)
• Annual declaration: Clubs will provide a description of matters to be notified to the IFR arising in the previous year, or a statement that there are no such matters.  These will include matters of interest to the IFR e.g new, or changes in the circumstances of, owners or officers

Regarding fan engagement, the relevant matters, for which the IFR is seeking views to inform its guidance on their meaning and scope, are:

• The club’s strategic direction and objectives
• The club’s business priorities
• Operational and match-day issues, including ticket pricing
• The club’s heritage
• The club’s plans for additional fan engagement

The IFR is proposing principles for adequate and effective consultation on the relevant matters designed to establish mechanisms that are:

• Collaborative: Clubs to seek fans’ input on the approach to and content of consultation
• Two-way: Fan representatives can input into club decisions before they are made
• Open: Clubs transparently provide fan representatives with information that is accurate, timely and (to the extent commercially and legally practical) complete
• Integrated: Fan’s views are considered in club’s decision making with outcomes openly shared

The IFR is also providing guidance on its expectations for the identification and selection of persons who are representative of fan’s views with whom clubs will consult.  These include criteria to be met by representatives and principles to be applied in electing fan representatives, when elections are held.

The IFR is also empowered to set bespoke discretionary licence conditions for both provisional and full licensing purposes to address specific risks at individual clubs, while licence awards are also dependent on compliance with so-called “freestanding duties”.  The latter are defined in the Act and include duties not to operate a team in a prohibited competition (e.g. a European Super League) or dispose of the home ground, relocate home games or change the club’s colours, crest or name without approval.

A full licence will be granted when a club is compliant with the mandatory conditions, any discretionary conditions and freestanding duties, and meets threshold requirements relating to financial and non-financial resources, as well as fan engagement.  The latter will be met when the club can show it has adequate and effective means of consulting its fans on relevant matters, and that it takes their views into account in decisions making on those matters.

Members wanting to read the IFR’s consultation document on the licensing regime and potentially submit comments can find it at: https://engage.footballregulator.org.uk/licensing-regime.  Alternatively comments can be submitted via RamsTrust at: membership@ramstrust.org.uk.