Guide
The IFR owners, directors and senior executives test: what your club should check
The regulator now decides whether the people who own and run a club are suitable. Most clubs will pass easily. The risk is in records that do not say clearly who those people are.
In short
- The IFR assesses the suitability of club owners, directors and senior executives. Powers over existing owners and senior managers applied from 12 December 2025, and approval of new ones from May 2026.
- An owner is anyone with more than 25% of the shares or voting rights, or who exercises significant control.
- The IFR looks at honesty and integrity, financial soundness, the source of wealth and, for senior roles, competence.
- The provisional licence application asks the same question from the club's side: a personnel statement naming every owner, the ultimate owner and every senior manager, which the club must publish once approved.
What the test is
Part 4 of the Football Governance Act 2025 gives the Independent Football Regulator powers over the owners and officers of regulated clubs. Sections 28 and 29 require a determination of suitability before someone becomes a new owner or a new officer. The regulator calls the regime the owners, directors and senior executives test.
According to law firm Lewis Silkin's summary, powers over existing owners and senior managers applied from 12 December 2025, and assessments of new owners and senior managers began in May 2026.
Who counts
- Owners: anyone holding more than 25% of the shares in the club or more than 25% of the voting rights, and anyone who exercises significant control.
- Directors: members of the club's board.
- Senior executives: the people performing senior management functions at the club.
The ownership threshold looks through holding companies. If the club sits under a parent company, an investment vehicle or a trust, the question is who ultimately holds more than 25% or controls the decisions.
What the IFR assesses
| Criterion | What it covers |
|---|---|
| Honesty and integrity | Criminal history, court findings, regulatory action and whether the person has misled authorities |
| Financial soundness | Personal insolvency and financial mismanagement at organisations the person was responsible for |
| Source of wealth | That the person's wealth does not come from serious criminal conduct |
| Competence | For senior management roles, the skills and track record for the specific position |
Where someone is found unsuitable, the consequences can include conduct restrictions, removal and, in extreme cases, a required sale. Financial penalties can reach 10% of the club's total revenue.
How it shows up in your licence application
The provisional licence application asks for the club's own account of the same people. Under the IFR guidance, the personnel statement must identify each of the club's owners and its ultimate owner, and each senior manager with their job title, role and senior management functions. Annex A question 2.2.4 asks for a group diagram showing the ultimate owners, the club and its key assets, and question 2.2.3 asks about expected ownership changes or investment.
Question 4.1.1 then asks why the personnel statement is accurate. Once the IFR approves the statement, the club must publish it online, and submit an update after any material change.
Answer the regulator's questions on time
The regulator's first enforcement step against a club was about information, not suitability. In July 2026 it issued a warning notice to the owners of National League club Morecambe after directors failed to reply to two requests for information, according to the Football Supporters' Association. A club that keeps its ownership and personnel records current can answer those requests quickly.
What to check now
- Draw the group structure from the top: every company, trust or fund between the club and the people who ultimately own or control it, with percentages.
- Check that the shareholder register, Companies House filings and the group diagram agree.
- List every director and senior executive, with a written role and reporting line for each.
- Note any ownership change, investment or sale under discussion, because question 2.2.3 asks about it.
- Name one person who will answer the regulator's information requests, and a deputy.
This is the ownership and control output in our service. We trace the group structure, draft the personnel statement with your team and resolve the inconsistencies before the club signs. Specialist legal questions about a particular owner stay with your lawyers. For the full application, see our provisional licence guide.
Questions clubs ask
What is the IFR owners, directors and senior executives test?
The regulator's assessment of whether the people who own and run a regulated club are suitable, under Part 4 of the Football Governance Act 2025. It covers owners above a 25% threshold or with significant control, directors and senior executives.
Does the test apply to existing owners or only new ones?
Both. Lewis Silkin reports that powers over existing owners and senior managers applied from 12 December 2025, and approval of new owners and senior managers from May 2026.
What does the IFR look at?
Honesty and integrity, financial soundness, the source of wealth and, for senior management roles, competence for the specific position.
Is the personnel statement public?
Yes. Once the IFR approves it, the club must publish the personnel statement online and update it after material changes.
Sources
- Football Governance Act 2025, Part 4, legislation.gov.uk
- Provisional licensing guidance, personnel statement, Independent Football Regulator
- Football club owners take heed: inside the IFR's new owners, directors and senior executives test, Lewis Silkin, 3 February 2026
- Morecambe become first club to face regulator action, Football Supporters' Association, 16 July 2026
Last updated . This article is general information about the published regime, not legal or financial advice for your club.