The Football Regulator
Governance, licensing and climate risk
The Independent Football Regulator (IFR) is a new statutory body set up by the UK Government. It is operationally independent and its main job is to protect and promote the financial sustainability of English men’s professional football.
As a newly established organisation, it is now asking for views on various aspects of how it should work, including a proposed licensing regime. This regime will require all clubs within scope to meet mandatory standards to obtain, and continue to hold, a licence to compete.
The consultation document explains the proposed regime and sets out 27 questions where the IFR is seeking views. The response I submitted focused on one of those questions - in relation to corporate governance - and is set out below.
As ever, all comments, corrections and clarifications on any aspects of this post are super welcome. Feel free to dive in - just not two-footed or studs-up!
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Q 19. Do you have any other comments on the IFR’s proposals for corporate governance?
This response relates to governance and risk oversight within the licensing regime, and is not intended to advocate for environmental regulation by the Independent Football Regulator (IFR). The IFR’s remit is not to set environmental standards. Rather, the objective here is to ensure that material financial and operational risks arising from climate-related disruption are properly recognised within clubs’ governance and risk-management frameworks.
During passage of the Football Governance Bill, the Minister explained that statutory intervention should be reserved for issues that football has been unable to resolve through self-regulation. Recent developments illustrate the limitations of voluntary approaches in this area. In 2024, the Premier League pledged to introduce a minimum environmental standard and to ensure that every club had a “robust environmental sustainability policy” by the end of the 2024/25 season. During the passage of the Bill in the House of Lords, the responsible Minister said this was a “good example” of effective self-regulation. However, despite now being in the 2025/26 season, there is no published evidence or reporting showing that this has been delivered consistently by Premier League clubs. Elsewhere in the football pyramid, only 32 of 72 clubs participate in the voluntary EFL Green Clubs/Green Code scheme.
These examples underline a wider challenge: voluntary standards can be unevenly implemented, particularly where they require sustained governance attention and long-term financial planning. This variability demonstrates the value of the IFR’s corporate-governance role, ensuring a consistent baseline of risk oversight across all clubs.
Government-commissioned research on the financial implications of climate change for grassroots sport was published by DCMS after the Football Governance Bill received Royal Assent. It provides new evidence that the IFR must now take into account when interpreting its governance responsibilities. The research confirms that climate-related disruption creates clear operational and financial risks through facility damage, match cancellations, increased maintenance and rising insurance costs.
Although the research focuses on community facilities, these financial pathways clearly scale with the size and complexity of elite football operations and therefore represent foreseeable impacts and shocks to club finances.
The IFR should ensure that clubs’ governance and planning frameworks are capable of identifying and managing any material risk to financial or operational sustainability, including climate-related risks where relevant. These foreseeable risks underline the need for a single Club Code that sets a common governance baseline across all licensed clubs, ensuring that material risks are identified and managed consistently throughout the football pyramid.
Although the IFR is not an environmental regulator, the financial and operational consequences of climate and environmental risks are now sufficiently clear that they warrant explicit recognition within the licensing regime. The IFR should therefore make clear in its Corporate Governance Code and licensing guidance that clubs are expected to maintain appropriate environmental or sustainability policies as part of risk management. These policies should be proportionate and relevant to each club’s circumstances, and linked to financial resilience.
Embedding this expectation within governance standards - supported by proportionate IFR guidance - would help ensure that clubs address significant long-term risks systematically, rather than relying on voluntary measures that are not delivered uniformly. To support consistent practice, the IFR should issue proportionate guidance to help clubs identify material operational and financial risks, including where climate-related disruption has business implications, while making clear that such guidance does not prescribe environmental policy or performance standards.
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Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
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Solid argument for embedding climate risk into governance frameworks. The gap between voluntary commitments and actual implementation is telling, especially when 32 of 72 clubs participate in the EFL scheme. The point about proportionate guidance hits the right balance: clubs need structured oversight without turning the IFR into an enviromental regulator. Financial materiality is the key link here, when climate disruptioncreates foreseeable operational costs, its a governance issue whether we call it environmental policy or not.