The Football Governance Act 2025 (the Act), which received Royal Assent in July 2025, represents a significant shift in the regulation of football in England. Moving away from industry-led self-regulation, the Act introduces a statutory framework overseen by an Independent Football Regulator (IFR) with wide-ranging powers.
While attention has largely focused on ownership rules and financial oversight, one of the most significant developments is the elevation of corporate governance. Governance, transparency and accountability now sit firmly at the centre of regulatory compliance.
Crucially, these changes apply across the football pyramid. This is not legislation limited to elite clubs, organisations of all sizes, including smaller and community-based clubs, must adopt more structured and demonstrable governance practices.
How the Football Governance Act 2025 Places Governance at the Centre of Regulation
The Act establishes a clear statutory objective: to protect and promote the sustainability of English football. Sustainability is defined broadly, extending beyond financial health to include long-term stability, protection of club heritage, engagement with supporters and wider community impact.
To meet these objectives, clubs must be able to demonstrate robust governance structures, effective board oversight, and clear decision-making processes with accurate and accessible records.
This represents a clear shift away from informal or owner-led decision-making towards accountable, process-driven governance.
Football Club Licensing Requirements and Ongoing Governance Obligations
A key feature of the Act is the introduction of a mandatory operating licence. Rather than a one-off approval, this creates an ongoing regulatory relationship with the IFR.
From a governance perspective, this brings new expectations, including:
- structured board and committee arrangements
- clearly defined decision-making authority
- regular, well-documented board meetings
- proper minute-taking and record-keeping
- formal risk management processes
Clubs must not only make appropriate decisions but must also be able to evidence how those decisions were made.
For many smaller clubs, governance has historically been less formal. The Act changes that. Even where resources are limited, clubs will be expected to implement governance frameworks that are proportionate but effective.
Early preparation will be key to avoiding regulatory risk and ensuring a smooth transition into the new regime.
How we can help
At Herrington Carmichael, our Company Secretarial & Corporate Governance team supports organisations of all sizes in navigating evolving regulatory requirements.
We can assist with:
- implementing proportionate governance frameworks
- supporting board and committee processes
- maintaining statutory registers and records
- preparing for ongoing compliance
- advising on governance best practice
Conclusion
The Football Governance Act 2025 marks the beginning of a new regulatory era. Governance is no longer simply best practice; it is a core compliance requirement.
Clubs that begin reviewing their governance arrangements now will be better positioned to meet regulatory requirements, minimise compliance risk and support their long-term sustainability.
To discuss how the Act may affect your organisation, or to find out how our Company Secretarial & Corporate Governance team can support your compliance and governance objectives, please contact us to get in touch with a member of our team.
