Having been initially established on an interim basis the IFR was activated in July when the Football Governance Act 2025 (the Act) was passed. This followed an extended period over which football had more than once undertaken to introduce more robust self regulation but failed to do so. Compounded by the threat of a European Super League – and the negative reactions to it – as well as the damaging financial imbalances in the game, government intervention became unavoidable.

The IFR’s objectives, as defined by the Act, are to:

• Protect and promote the financial soundness of regulated football clubs;
• Protect and promote the financial resilience of English football; and
• Safeguard the heritage of English football.

In doing this the IFR will set corporate governance standards for clubs, operate a club licensing regime, monitor compliance with requirements on financial regulation, fan engagement and club heritage, and introduce enhanced club owners, directors and senior executives’ suitability tests. It will also have the power to prevent regulated clubs from joining competitions that fail to meet defined criteria and which threaten the heritage and sustainability of English football.

David Kogan, the IFR’s first Chair, has committed to delivering change. However, in seeking to achieve its goals above, the IFR is also committed to act not as an “enforcement led” regulator (with its enforcement powers kept primarily as a deterrent only) but as an advocate for best practice, working constructively with clubs to pre-empt and address potential and emerging issues before they crystallise or become unmanageable. It will facilitate this through the allocation to each club of a specific supervisor, with whom the club will hopefully develop an open and positive working relationship.

More information on the IFR is available on its website at https://footballregulator.org.uk/.

Although it is still in its mobilisation phase the IFR has commenced its interaction with the 116 clubs of the Premier League, English Football League and National League, both collectively – there was a meeting in Manchester of senior IFR officials and all the clubs on October 8^th – and individually, with Derby County already engaged in direct dialogue with the Regulator as it gathers information in advance of the provisional licensing regime to take effect next summer.

In addition, the IFR has published consultation documents in connection with its responsibility to develop policies and procedures that will effect the practical application of various requirements of the Act. To date these comprise documents addressing:

• The Owners, Directors and Senior Executives Regime
• Information Gathering and Enforcement
• Sanctions
• The Licensing Regime
• The Internal Review Function

For the first three of these the consultation process has now closed, with RamsTrust having submitted comments. Consultation is still open for the final two, with that for the Licensing Regime document open until early December. The latter is of particular significance to supporters as it contains the IFR’s expectations for the application of the Act’s requirements for fan consultation – one of four mandatory license conditions. The Act requires clubs to conduct regular consultation with fan representatives on five “relevant matters”:

• 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 proposes to establish best practice principles for fan engagement to assist clubs in complying with the Act. The proposals indicate that fan engagement is expected to be collaborative, “two-way”, open and integrated. The last of these reflects the expectation that fans’ views will be considered in decision making impacting the relevant matters. This is in fact a criteria that will need to be met if a club is to meet the conditions required to achieve fully licensed status. Clearly this represents a tremendous opportunity for fans’ voices to be heard and as such is one we must seize and exploit responsibly.

RamsTrust members who might wish to contribute to the IFR’s consultation process or simply read the material, can access the consultation documents here: https://engage.footballregulator.org.uk/. Registration with the IFR is required to submit comments directly or, if preferred, they can be submitted via RamsTrust at: membership@ramstrust.org.uk.