ClubProof · 13/11/2026
The Football Governance Act 2025 introduced a statutory framework for football regulation. For club leadership, preparation is broader than a fan engagement policy. The IFR’s licensing framework brings together financial regulation, corporate governance and supporter engagement, with separate guidance and documents for different parts of the process.
The practical starting point is to establish which official requirements apply to your club and which records already support your response. This article focuses on organising that work. It does not replace the regulator’s current forms, your club’s licence conditions or professional advice about an individual submission.
Work from the official licensing documents
The IFR licensing page states that the regime covers the top five tiers of English football and that clubs competing in those divisions must obtain a provisional licence ahead of the 2027/28 season. It links the licensing rules, application guidance, governance code and reporting documents.
Create a source register containing the document title, link, version or publication date, date checked and person responsible for reviewing changes. A summary written last season may remain useful background, but it should not silently replace the latest official instruction.
Separate an application from ongoing obligations
The IFR distinguishes provisional licence application guidance from guidance on ongoing licensing obligations. Treat these as related but different workstreams. An application describes information needed for the licensing decision. Ongoing obligations concern what the licensed club subsequently maintains or reports.
In your internal plan, identify the relevant official document beside each task. Avoid assuming that one generic annual report will satisfy every request. Where a prescribed form or format is required, use the version identified by the regulator rather than recreating it in a branded document.
Prepare a responsibility and evidence map
Use a working register with the source reference, accountable executive, contributors, supporting records, internal review date and approval route. Label uncertainty explicitly. A task awaiting clarification should not appear complete merely because somebody has uploaded a file.
As a practical example, the governance statement workstream might draw on board responsibilities, risk oversight and stakeholder engagement records. The finance team may contribute different material to the strategic business plan. The board should understand those dependencies before approving the club’s response.
Explain governance practice, not just policy titles
The IFR Club Code operates on an apply and explain basis. Its principles are supported by recommended practices, with recognition that clubs have different circumstances. A useful explanation describes the club’s actual arrangements and how they support the principle being considered.
Ask which board discussion, review or decision demonstrates the practice. If a policy exists but has never been reviewed by the relevant decision maker, record that gap. Do not describe an intention to establish a process as if that process already operates.
Keep supporter engagement connected to decisions
Keep a separate but connected record of the matters raised by supporters, how the club considered them and what response followed. Meeting dates alone cannot explain the relationship between consultation and a decision. Preserve the relevant context without unnecessarily circulating personal information.
Set an internal review before the submission deadline
Confirm external dates directly from the current official guidance and communications for your club. Then work backwards to allow time for contributors, checks, board approval and any questions requiring clarification. This article deliberately does not create a new deadline or imply all clubs have the same circumstances.
ClubProof can support visibility of configured frameworks, requirements, team access and recorded activity today. Its planned evidence and reporting workflows are not a substitute for the IFR submission process. Discuss the current platform scope through Enquire now and use the official documents below as your source of regulatory instructions.