The UK Football Governance Act 2025: Key Changes for Owners and Investors

Overview

Institutional, state-backed and high net worth investors continue to target investments in English football, in part driven by the Premier League’s surging revenues (£6.4bn in 2024). Club valuations generally are trending upwards, as ownership continues to shift away from the United Kingdom. Many investment enquiries come from the US/Americas, no doubt seeking to replicate successful investments in NFL, NBA and MLS franchises.¹

The surge in overseas interest has coincided with the introduction of the UK Football Governance Act 2025 (the “Act”), which seeks to safeguard the heritage and financial soundness of clubs and of the game more generally. The Act has transformed the regulatory framework of the English league pyramid, introducing unprecedented levels of oversight: it establishes an operating licensing regime, a new owner and officer suitability test, club and competition organizer duties, a revenue distribution mechanism, and investigation, enforcement, review and appeal frameworks.

These rules will be overseen by a new Independent Football Regulator (the “IFR”), funded by an annual levy on clubs. The Act confers extensive investigative and enforcement powers upon the IFR, which has already signaled its intention to take an interventionist approach and, in February 2026, announced a memorandum of understanding on information sharing with the UK Financial Conduct Authority (the “FCA”).²

In this article we highlight the key issues arising from the Act and the proposed IFR, both for current owners and for those navigating potential investments in the game.

Application

The Act has a broad application, covering any body which operates a team within a specified competition (which encompasses the Premier League, English Football Leagues, Women’s Super League and WSL 2).

Although the Act came into force on 21 July 2025, the licensing regime, suitability assessments and enforcement powers will be phased in throughout 2026.

Key New Rules

The Act introduces several new regulatory mechanisms that will impact club ownership and operation.

Statutory Ownership Test

The Act brings in a statutory ownership test, overseen by the IFR. Those buying into or taking a senior management role at any club must pass the regulator's suitability assessment. For owners, this will consider factors such as the source and sufficiency of an owner’s financial resources. For those taking management positions, the assessment examines honesty and integrity, including whether the individual has been involved in financial misconduct, fraud or other dishonest behavior, as well as competence and capability to fulfil the relevant role.

Mandatory License Conditions

Every club must now hold an operating license to compete, which requires compliance with non-negotiable baseline requirements covering financial planning, governance and fan engagement (and may be subject to additional obligations imposed by the IFR on a case-by-case basis).

Crucially, clubs must submit detailed financial plans on an annual basis and whenever there is a material change in their financial position. They must adhere to these plans, and maintain appropriate financial resources to meet cash flows and demonstrate they are not wholly dependent on continued owner funding for survival.

When assessing financial compliance, the IFR will focus on actual cash reserves rather than accounting valuations, and player registrations and squad values will not count towards a club’s required liquidity. The IFR has not yet published guidance on the precise level of cash reserves clubs will need to hold, but owners should expect that they will be required to keep substantial funds available. Whether shareholder loans can count towards a club’s required funding base has not yet been confirmed.

There are also equivalent annual financial reporting requirements for ownership and management structures, and a requirement to regularly consult supporters on the direction of the club.

Heritage Protections and Competition Prohibitions

The Act creates several safeguards to protect what makes clubs special and prevent decisions that could damage their identity or financial stability. The IFR will hold powers to prohibit participation in new competitions, a power widely understood to be a direct response to the breakaway European Super League proposals in 2021.³ Clubs must also seek the regulator’s approval in respect of a wide range of activities, including: (i) selling, leasing, borrowing against or relocating a home stadium, (ii) changes to the club badge or primary kit colors and (iii) appointing administrators when in financial distress.

Revenue Distribution Powers

If leagues cannot agree on how to share broadcasting and other revenues, the Act gives the IFR the power to intervene and impose a binding solution:

• Mediation first: competition organizers can ask the IFR to help resolve disputes; the regulator must allow mediation for up to 28 days before imposing a solution.
• Binding decisions: if mediation fails, the IFR can issue a legally enforceable order on how money must be split.
• Overriding contracts: the IFR's order can override existing agreements between clubs or leagues.
• Duration: IFR orders will last for a specified term (typically aligned with broadcast cycles) and can only be changed in exceptional circumstances. In circumstances where leagues subsequently reach their own agreement, an IFR order will remain in place unless the IFR is satisfied the new arrangement meets the required standards.

The IFR’s powers

The regulator has been given extensive statutory powers to investigate issues and enforce compliance with the rules. These powers are broadly comparable to those held by the FCA and other major UK regulators. The IFR’s newly appointed chief executive, Richard Monks, a former FCA director, has signaled that the regulator will be a positive force for investment in the game while also making clear that it will not shy away from intervention where financial sustainability is threatened.⁴

Information Gathering

Investigative levers available to the IFR include:

• Production orders: the power to require clubs, owners, officers and third parties to hand over documents and data. Refusing without good reason may lead to fines and potential license suspension.
• Formal investigations: the IFR can bring in specialists to investigate and report on a club's finances, governance or operations where it suspects there has been a potential infringement of its rules. Clubs and specified individuals must cooperate fully and pay an appointed expert's fees.
• FCA collaboration: pursuant to a memorandum of understanding announced in February 2026, the IFR and the FCA have established a framework for the sharing of confidential information in order to facilitate the exercise of their regulatory functions. Information may be provided by either party in response to a written request from the other.  

Sanctions

The IFR has a range of powerful tools to punish non-compliance, with penalties tailored to the seriousness of the breach:

• Ownership Disqualification: if an owner fails the suitability test, the IFR can ban them from involvement in English football indefinitely and even impose a forced sale of their stake to an approved third party.
• License Suspension and Revocation: the IFR can revoke a club’s operating license in serious cases of non-compliance.
• Financial penalties: fines of up to 10% of club or group turnover (for clubs and owners respectively) or 10% of annual pay (for officers) may be levied, with daily fines for ongoing breaches.
• Public censure: the regulator can name and shame clubs and individuals.
• Remedial action: the IFR can appoint specialists to fix problems at the club's expense.
• Emergency powers: where an ongoing breach threatens its objectives, the IFR can issue orders requiring immediate action which take effect without prior warning.
• Criminal penalties: certain misconduct is considered criminal in nature, including destroying or falsifying required information, lying to the IFR, and obstructing officials. Offences carry up to two years in prison and unlimited fines.

Appeals and Review

To ensure fairness, the Act provides safeguards allowing people to challenge certain of the regulator's decisions:

• Internal review: anyone directly affected by a decision can request an internal review by an independent committee assigned by the IFR.
• External appeals: appeals to the Competition Appeal Tribunal are available for specified key decisions such as license refusals or revocations, bans, negative suitability determinations, distribution orders and financial penalties. Further appeal to the Court of Appeal would be available on points of law only, with prior permission required.

Next steps for owners and investors

Following a consultation which closed in February 2026, the IFR is currently producing its first report on the state of the game (which will be published in 2027) and has outlined the information it intends to seek from both clubs and leagues as part of an extensive consultation process. Following publication of the report, the IFR will consider the responses and then consult further on draft rules to give effect to the regime.

The IFR also recently launched a second consultation on the licensing regime, which deals with liquidity requirements and the treatment of shareholder debt, with responses due by 5 May 2026. It is expected that the final rules and guidance on the licensing regime will be published in Summer 2026.

The Act introduces significant new obligations on owners, investors and clubs, falling within an enhanced regulatory regime. This ensures that governance standards keep pace with the high levels of investment into the sport.  Time will tell how these obligations are imposed and enforced in practice, but while the Act is phased in and the IFR gets up to speed, it is crucial that owners and potential investors understand how the new rules will affect them (and how they differ from the rules imposed by individual leagues) and the steps they must take to ensure they comply with their obligations.