The Football Governance Act 2025: A Legal Analysis of What Has Changed

This article examines the differences between the text of the Football Governance Act 2025 with the final Bill published by the previous Government and analyses the impact that these changes could have. In summary, the following broad changes have been made to the legislation: 

1. A greater focus on consultation between the IFR and other stakeholders. In particular, the relationship between the IFR and the Football Association has been strengthened. 
2. A greater emphasis on how the IFR may act proportionally, in line with regulating clubs of different commercial size.  
3. A greater focus on how the IFR might be independent from government.  
4. Reform of the IFR’s power and approach to arbitrating a redistribution deal between bodies.  
5. In relation to the IFR’s configuration, a watering down of the role of the Expert Panel. 
6. Clarification on the meaning of ‘consultation’ with fans .
7. Additions to the definition of “Corporate Governance”, and requirements for the Corporate Governance Statement – in particular to include provisions related to equality, diversity and inclusion, and to the club’s contribution to the economic and social well-being of the local community
8. Greater fluidity on the shape of future regulation, through a five-year review of the IFR’s operation.  

The article analyses each of these areas in turn. 

In analysing the legislation however, more minor, technical changes have not been considered. The following are therefore not covered: 

1. Minor differences in language, with identical meaning 
   1. Numerical differences – the addition/removal of certain sections of the Bill means that there are slight differences between the numbering of sections, subsections, clauses and paragraphs. In cases where the article refers to a change within a certain section or clause, the number is that taken from the first (Conservative) Bill. Ie. If noting a difference in a Section that is numbered Section 57 in the Conservative Bill, and Section 58 in the Football Governance Act, the document will number it Section 57. 
   2. Clarifications of language which supplement definitions

Article Outline

• Greater focus on consultation between the Government, the IFR and other stakeholders
  • Consultation for competitions that fall under IFR’s scope
  • Consultation Requirements for the State of the Game Report
  • Discretionary Licence Conditions and Stakeholder Input
• Emphasis on the IFR acting proportionally
• Independence of the IFR from government
• Reform of the IFR’s power and approach to arbitrating a redistribution deal between bodies
  • Inclusion of Parachute Payments in Revenue Calculations
  • IFR has greater oversight over parachute payment related disputes
• Changes to the IFR’s Internal Constitution
  • Levy Structure & Funding Scope
  • Internal Reviews and Appeals Process
• Clarification on the meaning of ‘consultation’ with fans
  • Consultation For Relocation & Insolvency Proceedings
  • Defining Standards for Fan Consultation
• Definition of “Corporate Governance” expanded
• Section on review of the Act now added
• Conclusion