Impact assessment

Fact sheet - government amendments at Lords Report stage

Updated 27 March 2025

Applies to England and Wales

At Report Stage in the House of Lords in March 2025, the government made 24 amendments to the Football Governance Bill in total, which included some technical amendments. The details of these amendments are summarised below.

1. Financial growth

The Bill has been amended to add the ‘financial growth of English football’ into the Regulator’s secondary duties. The existing duties in Clause 7(2) have already been included with the intent of protecting the growth and success of English football, to guide the IFR (Independent Football Regulator) in its pursuit of sustainability. These duties require the IFR to have regard to the desirability of avoiding effects on sporting competition, and adverse effects on competitiveness (including international competitiveness) and financial investment. However, this amendment has been made to further strengthen these duties, with growth in mind, without overly constraining the Regulator. The IFR will now be obliged to have regard to the desirability of avoiding adverse impacts on the financial growth of English football.

2. Regulatory principles- light touch regulation and engagement with players and fans

The regulatory principles in the Bill have been amended to add players, fans and others who may be affected by the Regulator’s decisions to the list of persons the IFR should proactively and constructively engage with. As the primary workforce, football players play an important role in the industry, and some of the Regulator’s decisions are likely to indirectly impact them. In a similar vein, fans are likely to be indirectly impacted by the Regulator’s decisions which this amendment addresses.

A new regulatory principle has also been added that makes clear that the IFR should have regard to whether a requirement or restriction is necessary and if a similar outcome could be achieved by less burdensome means. This is to clarify the intention for the regulatory regime to be light touch.

3. Statutory review

In recognition that it is good practice for the impacts of regulation to be monitored and evaluated post-implementation, the Bill has been amended to add a requirement for the Secretary of State to carry out a review of the operation of the act, and its impact on the industry, no later than 5 years from the full commencement of the licensing regime.

4. Financial distributions

In addition, several changes have been made to clarify aspects of the financial distributions ‘final offer’ mechanism. These include clarifying that it is a mechanism of last resort and that the IFR should consider if the questions that need to be resolved could be resolved through its other functions before triggering the process.

This ensures the IFR cannot use the backstop as a heavy handed regulatory intervention in cases where a lighter touch regulatory function would have sufficed, therefore explicitly making it a ‘last resort’ power.

The Bill has also been amended to require the Regulator, in its notice to trigger the process, to outline any findings in its most recent State of the Game Report that it considers relevant to the question(s) for resolution. This makes it clear that the first State of the Game Report is to be published before the backstop mechanism can be triggered, as well as ensuring that all parties are clear from the outset of the process which findings will be considered relevant.

Through the changes made to the Bill, the mediator, appointed as part of the mediation phase, has been given the ability to request an extension from the IFR for the mediation phase of up to another 28 days. This will avoid parties being ‘timed out’ and the mediation phase coming to an arbitrary conclusion due to the statutory deadline, should the mediator identify that further useful discussion could take place.

It has also been clarified that, where parachute payments are deemed relevant to the questions for resolution, any final proposals submitted by the specified competition organisers must fully consider and account for relegated clubs finances, explaining how they will promote their financial sustainability.

5. Minor and technical changes

A number of other minor and technical changes have also been made to the Bill. These include:

A number of other minor and technical changes have also been made to the Bill. These include:

• Clause 8(d) has been amended in a minor drafting change to the regulatory principle in clause 8(d), changing “recognise” to “has regard to”. This is to ensure consistency in drafting with other parts of the Bill. 
• The Bill now explicitly requires the IFR to consult with each specified competition organiser and all regulated clubs before asking the Secretary of State to change the scope of its powers to attach or vary discretionary licence conditions under Clause 22. Previously the Bill required the IFR to consult “such persons as [it] considers  appropriate” before asking for any such change. 
• The minimum length of time that must have passed before the Secretary of State may publish a new football governance statement has been amended from three to five years. This is designed to reduce the probability of undue political influence on the IFR. 
• A requirement has been added for the IFR to establish a system for all Board members and Expert Panel members to declare relevant interests and to keep a register of these interests. In practice, this will mean Board and Expert Panel members must declare any relevant interests upon appointment and on an ongoing basis, and a record of these will be kept. This should ensure transparency and appropriate management of any conflicts.
• The power in Clause 92 (3)(a) to amend the definition of “football season” for the purposes of the Act has been removed. The original intention of this power was to allow the Regulator’s regime to keep pace with any future changes to the structure and definition of seasons in the industry. However the power has been removed as the risk of the definition in the Bill becoming outdated is low.
• Clause 49 and references in Schedule 4 have been amended to ensure that the legislation is consistent with heraldic terminology whilst remaining aligned with the pre-existing heritage requirements of the FA, so the Bill now mentions “crest or emblem”. 
• An upper limit has been added on how much interest can be charged on missed levy payments. This will prevent the IFR from being able to set a rate of interest for missed levy payments above the Bank of England base rate plus 5%. The IFR will maintain the discretion to set a rate of interest below this rate or to disapply interest entirely if the IFR deems it appropriate.
• The definition of corporate governance for football clubs in Schedule 5 has been expanded so that it now includes a club’s contribution to the economic and social well-being of its local community. This change does not specify any actions that need to be undertaken by clubs in order to meet the IFR’s code. However, it will encourage greater transparency around the community outreach work done by clubs.