The Independent Football Regulator

15 Aug 2025

At its latest meeting, the Blues Trust Board was joined by Martyn Henderson, the Interim Chief Operating Officer for the upcoming Independent Football Regulator (IFR), who kindly agreed to discuss the scope and implementation plan for the regulator, and what this could mean for fans. Below is a summary of the key points of the discussion outlining the scope of the regulator along with timescales and next steps.

Martyn is a senior Civil Servant who has held various key positions in the Civil Service and since January 2024 has headed up the transition team that is setting up the IFR.

The Football Governance Bill received Royal Assent last month and legal establishment of the IFR is now underway and will conclude in October (so at this point the IFR has no powers and cannot act). Martyn’s team has been building the organisation and structure for the IFR in readiness for its formal launch.

In terms of scope, the IFR will cover 116 clubs in the top 5 leagues (the Premier League, EFL and top division of the National League). It will only cover men’s teams.  Its role will be mainly concerned with financial regulation including strengthened owners and directors’ tests. What gives the regulator teeth, compared to today’s set up, will be its access to a wide range of data on owners and potential owners (e.g. from the National Crime Agency).

The IFR will also cover fan engagement, a governance code for clubs, protections for club heritage (stadium, badge, kit colours) and provide a backstop in terms of financial distributions between leagues (including parachute payments) if they cannot agree those amongst themselves – although this will likely be a reasonably lengthy process in terms of gathering data etc.

Just as important as to what is in scope are those things that are out of scope and Martyn was keen to make clear that sporting matters are NOT within the scope of the IFR and will remain the responsibility of the competition owners. This includes topics such as match scheduling, VAR, Financial Fair Play, and sporting sanctions, (e.g. points deductions). Martyn emphasised that the IFR will be very keen not to come into conflict with the competition owners over sporting matters – for example UEFA are happy with the proposed scope as it is but would likely take a dim view if the IFR strayed into sporting matters.

In terms of fan engagement, the IFR will have oversight of engagement which will be a condition of approved club licences. Engagement is expected to include strategic direction and objectives as well as day to day operational issues. There will be no “one size fits all” approach but clubs will be expected to follow good practice and consult meaningfully with fans, including supporter Trusts and other fan groups. The IFR will address concerns with clubs if they fall short on fan engagement but with a light touch approach to begin with. Each club will have an appointed IFR “supervisor” that fans themselves will be able to communicate with.

As preparation for this, the IFR will consult fans and organisations to establish good practice regarding fan engagement probably beginning in October 2025 once the IFR is up and running. The Blues Trust indicated that we would be keen to be part of this consultation alongside other fan groups.

There are several key steps in the set-up of the IFR expected imminently. These include confirmation of the Chair. The preferred IFR candidate is media rights expert David Kogan, who has been endorsed by the relevant Parliamentary Select Committee. Also included is the appointment of a CEO and appointment of a first batch of Non-Executive Directors. It is hoped that in future at least one of the non-execs will be primarily appointed based on their experience as a fan. Martyn himself will become Chief Operating Officer of the IFR.

Following the legal establishment of the IFR, the initial steps will be data gathering, engagement with key parties and surveys – including as mentioned with fans and fan groups – before publication of guidance, followed by a period of familiarisation for clubs before powers are fully implemented at the start of next season.

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