The new “senior managers” regime in English football: lessons from financial services and preparatory steps for clubs

The passing of the Football Governance Act 2025 (the Act) kicks off a new era in the governance of football in England, including the establishment of the Independent Football Regulator (IFR) with oversight over the top five men's leagues.

The Act borrows heavily from concepts in existing regulatory regimes, including the financial services sector. The extent to which the IFR will be inspired by financial services has been made clearer in the publication of a number of consultation papers setting out the IFR's draft rules and guidance on certain aspects of the new regime.

Of the new rules, one of the most notable proposals is the introduction of prescribed senior management functions (SMFs) for regulated clubs and further proposed guidance on the IFR's application of the Act's "suitability test" for determining an individual's capacity to fulfil these roles. Those with experience of the financial services industry will recognise these concepts as echoing the Financial Conduct Authority's (FCA) Senior Managers and Certification Regime (SMCR).

The IFR's proposals were published in its consultation paper on the new Owners, Directors and Senior Executives Regime (CP 1/25). The consultation closed at the start of October. If the senior managers regime is introduced as proposed in CP 1/25, clubs will need to take steps to ensure that their governance arrangements are compliant with the new regime. This article examines the IFR's proposals and the lessons we can learn from the SMCR:

• The new senior manager functions
• Suitability assessments applied to senior managers
• Preparatory steps for clubs