Insights Government publishes final report and recommendations of the independent Fan-Led Review of Football Governance


Following the attempt to set up a European Super League (ESL) in April 2021, which would have involved six English clubs as founding members being protected from relegation, the Government announced a fan-led review of football governance to explore ways of improving the governance, ownership and financial sustainability of clubs in English football.

The Review Panel met first in May 2021. It then heard evidence from a range of football stakeholders and in July 2021, it conducted an online survey, which received over 20,000 responses. Preliminary findings were published on 22 July 2021. The Review Panel has now published its final report.

Some of the key recommendations of the Review, include:

  • many clubs are poorly run, with reckless decision-making chasing an illusion of success and a disconnect between the interests of fans and owners; sophisticated business regulation tailored to the specifics of the football industry is needed; regulation needs to be led by an independent regulator, created by an Act of Parliament, which should be independent from football clubs and the Government, and have a clear statutory objective with strong investigatory and enforcement powers; the new Independent Regulator for English Football (IREF) should not operate in areas of traditional sports regulation which will be left to the existing authorities;
  • the new regime should be delivered through a new licensing system, administered by IREF, which would apply to the professional game (i.e. the top division of the National League and above); this would create a mechanism to enforce IREF’s requirements on clubs and allow IREF flexibility to introduce requirements tailored to address the problems identified in the industry, adjusted for different sized clubs, as well as to adapt these, in time, as the landscape changes;
  • the IREF should oversee financial regulation in football; the Review proposes a new approach based on regulatory models operated by regulators in other industries, e.g., the Financial Conduct Authority; financial regulation needs to consider five important factors: (i) ensuring long-term financial stability; (ii) avoiding monopolisation of leagues; (iii) international competitiveness; (iv) minimising burdens on clubs or an expensive system; and (v) ensuring compatibility with other rules (for example UEFA);
  • the IREF should replace the existing tests of ownership with a single test for owners, and a different test for directors, both of which should be subject to ongoing monitoring and include disqualifying conditions;
  • a new, compulsory corporate governance code for football, based on the UK Sport and Sport England Code for Sports Governance and including proportional requirements with greater demands on clubs in the Premier League as compared to National League clubs;
  • each club should have an Equality, Diversity and Inclusion Action Plan, which would be assessed as part of the annual club licensing process, to be approved and monitored by the IREF;
  • the IREF should set a minimum baseline of supporter engagement across all licensed clubs, and each club should be required to have a “Shadow Board” of elected supporter representatives, which would be consulted by the club on all material off-pitch matters;
  • to protect club heritage, each club should be required to provide for a special share, called a “Golden Share”, in its Articles of Association to be held by a democratically run Community Benefit Society set up under the Cooperative and Community Benefit Societies Act 2014, for the benefit of the club’s supporters; the Golden Share would require the consent of the shareholder to certain actions by the club, e.g., selling the club stadium or permanently relocating it outside its local area;
  • a recommendation that the Premier League guarantees its support to the football pyramid and make additional, proportionate contributions to further support football;
  • women’s football should be treated with parity and given its own dedicated review; and
  • the welfare of players exiting the game urgently needs to be better protected, particularly at a young age.

To access the Review in full, click here.