Law firm Lewis Silkin has warned clubs and their owners as the Independent Football Regulator gets to work

Law firm Lewis Silkin has urged football clubs and prospective owners to prepare for the Independent Football Regulator’s new owners and senior executives regime, warning that the statutory test brings tighter disclosure duties, upfront approval requirements and ongoing accountability once a person is in control. The firm’s briefing focuses on the regulator’s Owners, Directors and Senior Executives (ODSE) test, which sits within the IFR’s wider licensing system for English clubs. Lewis Silkin notes the ODSE regime has been in force for incumbent owners and senior managers since 12 December 2025, with assessments for new owners and senior managers expected to begin in May 2026. “The regime turns on transparency, approval and ongoing accountability,” Lewis Silkin wrote, adding that clubs and individuals must notify the IFR when there is a “reasonable prospect” that someone will become an owner.The firm said the trigger is likely once a club has identified a bid likely to result in a new owner, rather than requiring notification of every approach. Lewis Silkin set out how the definition of ‘owner’ extends beyond simple shareholdings, capturing those with more than 25% of shares or voting rights, those with the ability to appoint or remove an officer, and anyone with “significant influence or control”, including indirect arrangements through corporate structures or trusts. On suitability, the firm said owners will be assessed on honesty and integrity, financial soundness and whether they have sufficient resources to support the club, alongside scrutiny of whether wealth comes from serious criminal conduct.It added that honesty checks can cover criminal matters outside the UK, court or tribunal findings, regulatory or disciplinary action, immigration and sanctions status, and cooperation with regulators. The briefing also warns that approval is not permanent. Lewis Silkin said the IFR can reassess suitability if it receives information raising grounds for concern, and can remove or ban an owner or issue directions limiting what they can do at a club, with decisions subject to review and, where applicable, appeal routes.Lewis Silkin also highlighted potential personal exposure for owners who breach IFR rules, including failures to notify, failures to comply with directions, or obstructing certain individuals. The firm said maximum financial penalties for owners may be set at up to 10% of a club’s total revenue, or a daily rate linked to 10% of daily revenue, or a combination, with a possibility that requirements may evolve as the IFR develops its ‘State of the Game’ work.The regulator is consulting on the terms of reference for that report, with the consultation scheduled to close at 5pm on 17 February 2026.