Duncan McCabe
In July of this year, the UK government passed the Football Governance Act (“the Act”) in capping years of concern over a lack of regulation in English football. The Act shifts authority over football clubs from private owners and into the hands of fans and the government.
In April of 2021, six English football clubs known as the “Big Six” announced plans to withdraw from the UEFA Champions League, the preeminent tournament in world football. The Big Six intended to join six other European football giants to create a new “European Super League.” Unlike the meritocratic Champions League, the new Super League would be open to only the wealthiest clubs in European football.1 Supporters of big clubs and small clubs alike took to the streets to express outrage at the announcement. Their chants had a common theme: greedy club owners were stealing the future of English football.2
In response, the Big Six backpedaled and announced plans to withdraw from the European Super League.3 However, backpedaling was not sufficient for the UK government. Officials had already expressed concern at the lack of football regulation in 2019 when Bury F.C., a century-old club playing in England’s 3rd division, collapsed in the wake of its owners’ wanton financial mismanagement.4
With Bury’s collapse fresh in mind, the Super League incident spurned regulators to launch a “fan-led review” into improving the “governance, ownership, and financial sustainability of clubs in English football.”5 The recommendations of that review became the Football Governance Act.6
The cornerstone of the Act is the establishment of an Independent Football Regulator (IFR) to protect and promote “the financial soundness,” “resilience,” and the “heritage of English Football.”7 In accordance with this goal, regulated clubs must obtain an operating license from the IFR.8 The IFR will condition licenses on certain threshold requirements including an applicant’s financial resources, experience and qualifications of club officers, and fan inclusion in club decision making.9 Moreover, the IFR may impose discretionary requirements on a club’s liquidity and debt if such a requirement would promote the club’s financial resilience.10 Clubs will have to submit and abide by annual plans that demonstrate continued compliance with the IFR’s license requirements.11 Clubs that violate license requirements are subject to censure, fine, or license revocation.12
In addition to the IFR’s largely discretionary license requirements, the Act imposes explicit duties on regulated clubs. Clubs may not join leagues which the IFR deems “prohibited.”13 Nor may clubs modify their stadium, relocate their home grounds, or change jersey colors without input from fans and approval from the IFR.14
The Act also limits who is eligible to own and operate a regulated football club. Owners must demonstrate to the IFR that they have sufficient finances to support a club, a reputable source of funding, and an upstanding character.15 If the IFR finds that an incumbent or prospective owner is financially unsound or lacks “the requisite honesty and integrity,” the regulator may demand a stepdown or block the transfer of club ownership.16
Lastly, the Act grants the IFR the authority to settle disputes between leagues over the distribution of league revenues.17 However, the IFR can exercise the settlement power only if the leagues are unable to reach an agreement on their own.18
The ramifications of the Football Governance Act won’t be certain until the IFR begins issuing rulings. However, the potential benefits are both clear and closely aligned with the outrage fans expressed four years ago. Under the Act, clubs must consult fans on major operational decisions, financially reckless owners are subject to meaningful oversight, and historic elements of English football receive protection.
The critiques of the Act are just as clear. Part of the reason owners wanted to join the European Super League was to increase television revenue while eliminating the risk of failing to qualify for the Champions League.19 If the IFR has discretion to intervene in such decisions, investors may choose to keep their money out of English football. For now, the English Premier League brings in—by far— more revenue than any other domestic football competition in the world.20 But anything can happen in football. If investors begin to leave, so too may the fans.
[1] See Tom Hamilton, Super League Collapses: How Fan Reaction, Revolt Helped end English Club’s Breakaway, ESPN (Apr. 22, 2021), https://www.espn.com/soccer/story/_/id/37616441/how-fan-reaction-revolt-helped-end-english-clubs-breakaway [https://web.archive.org/web/20251024170701/https://www.espn.com/soccer/story/_/id/37616441/how-fan-reaction-revolt-helped-end-english-clubs-breakaway].
[2] See id.
[3] See id.
[4] See David Conn, Series of grinding Failures That left Proud, Historic Bury in Ruins, The Guardian (Aug. 27, 2019), https://www.theguardian.com/football/2019/aug/27/bury-historic-club-football-league-financial-ruins [https://web.archive.org/web/20251116015740/https://www.theguardian.com/football/2019/aug/27/bury-historic-club-football-league-financial-ruins].
[5] Department for Culture, Media, & Sport, Fan-Led Review of Football Governance: Securing The Game’s Future: Executive Summary (2021), https://www.gov.uk/government/publications/fan-led-review-of-football-governance-securing-the-games-future/fan-led-review-of-football-governance-securing-the-games-future [https://web.archive.org/web/20251116020501/https://www.gov.uk/government/publications/fan-led-review-of-football-governance-securing-the-games-future/fan-led-review-of-football-governance-securing-the-games-future].
[6] Lorraine Mckenna, ‘Historic’ Football Regulator Bill Becomes Law- What it Means for Fans (July 21, 2025), BBC https://www.bbc.com/sport/football/articles/c628yqmv8glo [https://web.archive.org/web/20251116020855/https://www.bbc.com/sport/football/articles/c628yqmv8glo].
[7] Football Governance Act 2025, c. 1, §§ 5,6. Notably, the Act does not specify which leagues the IFR will regulate; however, legislative comments indicate that the IFR will have jurisdiction over the top five male leagues of English professional football. See Department for Culture, Media & Sport, Fact Sheet: Football Governance Act (2025), https://www.gov.uk/government/publications/football-governance-bill-2024-supporting-documents/fact-sheet-overview [https://web.archive.org/web/20251116021201/https://www.gov.uk/government/publications/football-governance-bill-2024-supporting-documents/fact-sheet-overview].
[8] Football Governance Act 2025, c. 1, § 15(1).
[9] See id. sch. 4(2)–(4).
[10] See id. §§ 21, 22.
[11] Id. sch. 5.
[12] See id. sch. 9.
[13] Id. § 45(1)–(3).
[14] Id. §§ 46, 48, 50.
[15] See id. § 26, 28, 38.
[16] Id. § 26(7).
[17] Id § 56(1). Generally, the top English football league, the English Premier League, distributes some of its revenue to the lower leagues. This provision allows for the IFR to set the amount of revenue the Premier League must share. See Matt Slater, Premier League to Share More Income With EFL Clubs, N.Y. Times (Apr. 24, 2023), https://www.nytimes.com/athletic/4446932/2023/04/24/premier-league-efl-income-steve-parish/ [https://web.archive.org/web/20251024164935/https://www.nytimes.com/athletic/4446932/2023/04/24/premier-league-efl-income-steve-parish/].
[18] Football Governance Act 2025, c. 1, § 56(1)(b).
[19] See Alex Kirshner, European Soccer’s New Gambit is Following American Football’s Playbook, Slate (Apr., 19 2021), https://slate.com/culture/2021/04/european-super-league-soccer-nfl-college-football.html [https://web.archive.org/web/20251024170147/https://slate.com/culture/2021/04/european-super-league-soccer-nfl-college-football.html].
[20] List of Professional Sports Leagues by Revenue, Wikipedia, https://en.wikipedia.org/wiki/List_of_professional_sports_leagues_by_revenue [https://web.archive.org/web/20250907224646/https://en.wikipedia.org/wiki/List_of_professional_sports_leagues_by_revenue] (last visited Sep 7, 2025).