The Independent Football Regulator (IFR) has published three new consultations as it begins its work of implementing the Football Governance Act 2025 (previously discussed here).

The first consultation sets out the IFR’s proposed ‘ODSE regime’ which will assess the suitability of owners, directors, and senior executives. As the IFR explains, anyone seeking to become an owner of a regulated club, or to take up a key senior position within the club, will need to be approved by the IFR. The consultation first sets out who will be within the scope of the ODSE regime, before explaining the IFR’s approach to assessing suitability, applying the Act’s criteria of (i) honesty and integrity; (ii) financial soundness; and (iii) in the case of Senior Managers only, competence. The consultation also provides detail on what the IFR proposes by way of an application process for those wishing to be approved by the IFR, as well as how the suitability of those in incumbent positions will be assessed.

The second consultation is more procedural in nature and sets out the IFR’s approach to its information gathering and enforcement powers. It is accompanied by draft guidance which explains, among other things, the type of information the IFR will likely want to obtain, when certain information may be withheld, and the potential consequences of failing to comply with an Information Notice. On the matter of enforcement, the draft guidance also provides details on when the IFR will take enforcement action, as well as what happens during an enforcement investigation. However, the consultation is clear that the IFR “will not act as an ‘enforcement-led’ regulator” and instead intends to work constructively with clubs and ensure that “issues and risks of parties breaching their obligations are addressed before they crystallise”.

Finally, the IFR is consulting on how it proposes to determine the appropriate type and level of sanction. It explains that it intends to use a ‘stepped approach’ which will determine the seriousness of the breach before considering whether any adjustments are appropriate for aggravating or mitigating factors, as wells as whether the proposed sanction is proportionate.  The consultation also explains how the various sanctions will work and the procedural steps that the IFR will follow, and sets out a helpful table of relevant infringements alongside the available sanctions that might apply to them.

All three consultations close on 6 October 2025, and can be read here.