The Football Governance Act 2025 introduces practical governance obligations that football clubs must now implement and evidence. Under the oversight of the Independent Football Regulator (IFR), governance is no longer theoretical; it must be clearly demonstrated in practice.
These requirements apply across all tiers of the game, requiring clubs to review and, where necessary, enhance their governance arrangements.
Football Club Ownership, Control and Board Oversight Requirements
The Act introduces a statutory suitability regime for owners and senior officers, increasing scrutiny over those exercising control or influence.
Boards must maintain clear oversight of their ownership and control structures, sources of funding, changes in influence or control and the suitability and integrity of directors and senior management.
This requires improved transparency and more formalised governance processes, particularly where arrangements have historically been informal.
Fan Engagement and Club Heritage Protection Under the Football Governance Act 2025
A notable feature of the Act is the recognition of fans as statutory stakeholders. Key decisions such as those relating to club identity, stadiums or competition participation must now involve:
- structured consultation processes
- formal governance procedures
- documented board-level consideration
This embeds stakeholder engagement within governance frameworks, requiring clubs to approach such decisions in a structured and accountable manner.
Independent Football Regulator Oversight and Governance Risk Management
The IFR has extensive powers, including the ability to require information and documentation, investigate governance and compliance failures, impose sanctions or, in serious cases, revoke licences.
As a result, governance becomes a central risk management function. Clubs should ensure:
- consistency between board decisions and regulatory submissions
- accurate and up-to-date records
- clear audit trails supporting key decisions
The company secretarial function now plays a key role in supporting compliance by coordinating governance and board processes, maintaining statutory and governance records, supporting regulatory engagement and ensuring procedural compliance.
For many clubs, particularly those without internal resources, external governance support may be essential to meet these requirements effectively.
How We Can Help
Herrington Carmichael’s Company Secretarial & Corporate Governance team supports clubs and organisations of all sizes in managing these practical governance obligations. We can assist with:
- governance reviews and gap analysis
- board and committee framework implementation
- statutory compliance and Companies House filings
- governance documentation and minute-taking
- preparation for regulatory engagement and scrutiny
Conclusion:
The Football Governance Act 2025 marks a shift towards stricter and more transparent regulation. Governance is no longer optional, it sits at the heart of compliance.
Clubs that act proactively will be better placed to manage regulatory scrutiny and support long-term sustainability.
If you would like advice on governance structures, board processes, statutory compliance or preparing for regulatory scrutiny, please contact Herrington Carmichael’s Company Secretarial & Corporate Governance team. Contact us to discuss how we can support your club.
