A recent study reveals that only a tiny fraction of English football clubs are adequately prepared for the forthcoming independent regulator. According to the Fair Game Index, a mere four clubs across the top four divisions—Brighton, Cambridge, Carlisle, and AFC Wimbledon—are currently "regulator ready". This finding raises significant concerns about the readiness of the remaining 88 league clubs as the new regulatory regime approaches.
The Independent Football Regulator (IFR) was established by the Football Governance Act 2025, marking a watershed moment for the sport in England. The IFR's core objectives are to protect the financial soundness of football clubs, promote financial resilience, and safeguard the heritage of English football. The regulator will have the power to operate a licensing regime, monitor and enforce compliance with financial regulations, ensure fan engagement, and protect club heritage. It will also introduce a more stringent owners, directors, and senior executives test (ODSE).
The Fair Game Index assessed 164 clubs, extending beyond the top four divisions to include teams in the National League North and South. The index considered various factors, including finance, governance, fan engagement, transparency, ethics, diversity, environmental practices, and community engagement. The results indicated that while 75% of Premier League clubs are technically solvent, only 5% possess cash reserves to cover three months of operating costs. Furthermore, only 29% of clubs in the top four divisions have a wage-to-revenue ratio of 70% or less, the limit imposed by UEFA's financial sustainability regulations.
The IFR's creation was spurred by the attempted breakaway European Super League and the financial collapse of clubs like Bury. The regulator aims to ensure clubs are financially sustainable and accountable to their fans. It will have the authority to set corporate governance standards and prevent clubs from joining competitions that threaten the integrity and sustainability of English football. The IFR's powers will also extend to imposing financial settlements between the Premier League and the English Football League regarding the distribution of television revenue.
The IFR will implement a licensing regime, requiring clubs to demonstrate compliance with financial and corporate governance standards to obtain an operating license. Provisional licenses, valid for up to three years, will be issued initially, with the IFR collaborating with clubs to meet the minimum criteria. Permanent licenses will follow, but can be revoked for persistent non-compliance. The regulator will also scrutinize and approve changes in club ownership, applying stringent criteria of honesty, integrity, and financial soundness.
The IFR's establishment is expected to be completed in the autumn of 2025, with an independent board and a Chief Executive Officer in place. The regulator has initiated consultations to gather feedback on proposed policies related to owners, directors, and senior executives tests, information gathering and enforcement, and sanctions.
While the IFR is widely supported, some concerns remain. Premier League chief executive Richard Masters has called for "light touch, proportionate regulation," cautioning against harming the financial and cultural value of the league. Legal challenges from clubs are also anticipated, potentially focusing on competition law principles and the regulator's proportionality. David Kogan, expected to chair the IFR, stressed the need for the regulator to be "absolutely watertight" to withstand such challenges. The IFR could also face legal challenges regarding the ability to block English football clubs from joining a breakaway new European Super League.
Despite these challenges, the IFR represents a significant step towards ensuring the long-term financial stability and sustainability of English football. By setting standards for financial management, fan engagement, and club heritage, the regulator seeks to prevent the crises that have plagued the sport in recent years. However, the fact that only four clubs are currently prepared for the new regulatory environment underscores the significant work that remains to be done.
