English football's new regulator to hand clubs and investors 'state of the game' scorecard
Published on 10th March 2026
The IFR's report will look to tackle the contentious areas of club finance, ownership structures and parachute payments
At a glance
The IFR is poised to set the regulatory tone for English football's governance, licensing and financial oversight for years ahead.
Parachute payments, promotion and relegation pressures, and ownership structures are among the defining issues its report is expected to confront.
Clubs, investors and rights holders will need to understand how the IFR's emerging framework may affect their financial planning and governance arrangements.
English professional football is entering a new regulatory era. The Independent Football Regulator (IFR), established under the Football Governance Act 2025, is preparing its inaugural "state of the game" report – a landmark exercise that will shape how clubs are licensed, funded and governed for years to come.
Osborne Clarke has submitted a detailed response to the IFR's consultation on the proposed terms of reference for the report.
Parachute payments
One of the most contested issues in football finance is the role of parachute payments – the funds the Premier League pays to recently relegated clubs – and their effect on competitive balance. Clubs without these payments face strong incentives to over-invest in pursuit of promotion, creating systemic financial risk across the Championship.
Osborne Clarke has urged the IFR to evaluate alternative distribution approaches, including graduated payments and "solidarity" mechanisms, to help build a fairer, more stable pyramid.
The 'cliff edge'
Promotion and relegation transitions represent the single most significant liquidity stress point in football finance. Clubs routinely enter wage commitments predicated on sustained league status, creating severe cash-flow mismatches upon relegation – a "cliff edge" phenomenon for financial resilience.
Momentum is building on the IFR to map these pressure points systematically so that licensing conditions can be calibrated to prevent foreseeable financial failures before they occur.
Ownership structures
The IFR should assess the balance between equity financing and shareholder loans, group structures and related-party arrangements against its financial soundness and owner suitability tests.
There have been calls for a comparative look at ownership models used in other leading leagues, such as Germany's "50+1" rules and Spain's member-based structures: not to import them wholesale but to draw lessons that can inform proportionate, fit-for-purpose regulation in England.
Osborne Clarke comment
The state of the game report represents a critical opportunity to establish the analytical foundation for effective, commercially aware regulation of English football.
Our Sports and Entertainment team is uniquely placed to guide clubs, investors and rights holders and combines specialist football regulation expertise with capability in finance, governance and competition law – drawing on this extensive expertise for its input into the IFR consultation. For further information, please contact one our experts.
