Temporary appointments and owner suitability - A practical guide to the IFR's 2026 changes
The Independent Football Regulator (IFR) between 17 March and 10 April 2026 consulted on changes covering two distinct areas:
- temporary appointments to Senior Management Functions (SMFs) during unforeseen absences, and
- a series of technical and clarificatory amendments to the Owners, Directors and Senior Executives (ODSE) regime.
It published its response[1] on 1 May 2026, with changes effective from 5 May 2026.
The changes carry practical implications for clubs, investors and senior individuals across English football. The authors appreciate that the volume and detail of the IFR's evolving regulatory framework can feel complex and extensive. With that in mind, this article sets out a brief executive summary of the key changes below, and then a longer piece delving into the latest regime changes in more detail.
The article looks at:
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- Tags: Football | Independent Football Regulator | Regulation
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Written by
Wendy Saunders
Wendy specialises in both advisory and contentious financial services regulation and is Co-Head of the Financial Services team at Lewis Silkin. She started her career in the Enforcement division of the Financial Services Authority (now Financial Conduct Authority) before moving into private practice, which has included secondments to Lloyds Banking Group and Macquarie.
She is very well connected across the firm to provide clients with a seamless and comprehensive service, ranging from employment matters such as SMCR, fitness and propriety and remuneration, corporate matters concerning change in control for financial services firms, advertising advice for a wide range of businesses concerning financial promotions, to outsourcing, e-money and payment services advice for the firm's digital, commerce and creative clients. Not to mention her particular specialism in crypto-related matters.
She advises a very wide range of clients, from banks, financial institutions and investment firms through to advertising agencies, games platforms and cryptoasset firms.
Giorgia Merighi
Giorgia is an Associate in the Employment team at Lewis Silkin, advising employers and individuals on a broad range of contentious and non-contentious matters. She has a particular interest in contentious work, including advising on Employment Tribunal claims and High Court litigation. She also has significant experience in workplace investigations, having conducted a sensitive and complex investigation involving numerous witnesses and allegations of inappropriate language and behaviour spanning several years on a TV production set.
During her training contract at the firm, she gained broad experience across a number of practice areas. She spent 8 months with the Employment team, focusing on contentious and investigations matters. She also completed a secondment to the Employment Legal team at Creative Artists Agency, a leading entertainment and sports agency, where she provided comprehensive support on a wide range of employment and HR matters across the company's global operations. She further spent 6 months in the Digital, Creative and Commerce team, advising clients on matters ranging from general commercial agreements, including sale of goods and services and drafting or reviewing terms and conditions, through to IP-heavy deals such as sponsorships and branded content agreements, and advertising-specific work including media buying agreements and advice on advertising regulation and clearance. She then spent 6 months in the firm's Dispute Resolution team, obtaining extensive experience in debt recovery and commercial disputes, including obtaining injunctive relief and managing fast-moving matters.
