The State of the Game Report
A response to the consultation on its Terms of Reference
Introduction
This post focuses on English men’s professional football and on a key part of the new Independent Football Regulator’s (IFR) work: assessing the state of the game.
At the same time, the core point is transferable across all of football - climate risks have important financial impacts, and the game has barely started to understand, quantify, and respond to them.
Context
English football is about to get its first ever State of the Game report, produced by the new IFR set up by the UK Government. The report is intended to take a hard look at the main pressures on the game and ask whether any of them threaten the regulator’s core objectives: financially sustainable clubs, a resilient pyramid, and protection of football’s heritage.
The Chair of the IFR says that “The game has never been examined like this before … [and the report] … will give football the clarity it deserves, so decisions by the IFR can be made with confidence and for the long-term.” The IFR’s chief executive adds that it “will be the most in-depth assessment of the football industry ever conducted” to “scrutinise decisions, challenge existing practices, and ensure clubs meet expected standards.”
This makes it critically important that the State of the Game report is fit for purpose in its focus. The IFR is taking a staged approach: a draft report later this year, a final report in 2027, and then new reports every five years. They are currently consulting on the terms of reference for this work (closing 17th February 2026), and I’ve submitted a response.
Consultation response
In summary, my response makes five key points:
Inclusion of climate risk: The State of the Game report should directly analyse climate-related financial risks to English football. Climate change poses material threats to both football’s systemic resilience and individual clubs.
Macroeconomic context: UK authorities recognise climate change as a major macroeconomic and financial stability risk. For instance, the Bank of England says “climate and transition shocks increasingly shape the macroeconomic outlook and financial risks”. The IFR’s State of the Game report Terms of Reference explicitly includes “resilience to macroeconomic shocks”. Omitting climate factors would therefore be inconsistent with that focus.
Sectoral linkages: Climate risks compound football’s economic vulnerabilities (e.g. broadcast revenue, debt, reliance on outdoor matches). Research for the UK Government’s Department for Culture, Media and Sport estimates that weather‑related disruption already costs UK grassroots sport over £320 million a year. Recent analysis by the World Economic Forum suggests over 90% of media rights and most sponsorship revenue in professional sport depend on outdoor activities, putting these income streams at direct risk from environmental disruption. My consultation response also looks in-depth at one of these vulnerabilities as an example: debt and credit vulnerabilities.
Club disclosures: Several top Premier League clubs and The FA already report climate-related risks in their financial statements, albeit inconsistently. This shows climate factors are financially relevant, creating a need for IFR analysis of them and of clubs’ climate-related financial controls.
Distributional impacts: Climate impacts vary across the football pyramid. Wealthier clubs can invest in resilience and access favourable financing. Lower‑league clubs already see more postponements and face higher relative costs, with less capacity to adapt. Given the IFR’s remit on financial soundness and revenue distribution, the State of the Game report should examine how climate risks and adaptation capacity are distributed across the pyramid.
These points are explained in more detail in my consultation response, each linked to the IFR’s statutory objectives and Terms of Reference.
Following on from them the response concludes with five key recommendations. The IFR should:
Explicitly include climate risk in its macroeconomic analysis
Commission an independent analysis of climate impacts on football finances
Integrate climate risk into financial soundness assessments and licensing (proportionally, reflecting club sizes and resources)
Address distributional concerns through monitoring and dialogue
Engage with relevant financial regulators to understand how climate-related lending and insurance practices could affect club financing
To ignore climate risks would be out of step with how financial risk is already understood elsewhere in the economy, and would leave football detached from economic realities. This is not about regulator scope creep. It’s about examining these issues through the strictly financial lens that proponents of the IFR have called for. From the macro to the match level, the case is clear.
You can read my full response to the State of the Game Terms of Reference consultation here.
This newsletter has no funding behind it - your support will keep it free, open, and running. Any contribution makes a real difference. If you’re able, please chip in to help keep it going.
Subscribe to the newsletter here. It’s free!
Fran James (he/him)
Football and Climate Change Newsletter
info@footballandclimate.org
LinkedIn | Bluesky | X