When the Regulator comes calling: how clubs should prepare for the Independent Football Regulator's information-gathering powers

The financial demise in the last decade of football clubs such as Bury, Derby County, and more recently Reading and Sheffield Wednesday finally handed the UK government the political impetus it needed to wade into the financial affairs of football. Enter the Football Governance Act 2025^[1] (FGA 2025). 

The FGA 2025 has established a new supervisory body, the Independent Football Regulator (IFR), to oversee clubs in the top five tiers of league football in England and Wales. The IFR’s headline objectives (see here^[2]) are to promote financial sustainability, enforce stricter standards for owners and directors, and increase fan engagement, all with the aim of protecting and promoting the sustainability and heritage of clubs within the modern game. However, beneath the headline objectives lies a deeper, less discussed (but in the author’s view potentially more troubling) implication for football clubs: the IFR’s broad statutory powers to both obtain information when undertaking its tasks and potentially to share it with other agencies.

This article considers the scope of the IFR’s information-gathering powers, and how information it gathers may be passed to other investigative and prosecutorial authorities. It then sets out what clubs should expect when an information notice arrives, the risks of getting a response wrong, and the practical steps legal teams can take now to be ready.

Article overview

• The IFR’s wide-ranging powers
  • Information gathering
  • Information sharing
• What does this mean for clubs and in-house legal teams in practice?
  • Control and visibility
  • Having systems in place early
  • Accuracy over speed
• What can clubs be doing now?