The IFR’s ODSE Regime: A material shift for clubs from May 2026

On 12 December last year, the Independent Football Regulator’s powers relating to the screening and approval of football club owners, directors and senior executives were formally activated.

The Owners, Directors and Senior Executives Regime (ODSE Regime) is designed to raise the standard of vetting and monitoring for senior individuals at clubs in the top five tiers of the men’s game. 

Certain elements of the new ODSE Regime are already in force – most notably the IFR now has powers to take action against any potentially “rogue” existing club owners, directors and senior executives. As of 5 May, these powers will be extended into the full ODSE framework covering new owners and appointments of directors and senior executives. Clubs will therefore need to factor the new ODSE Regime into any senior appointment processes. Many senior-level recruitment decisions taken from that point onward will require regulatory engagement and approval.

The publication of the IFR’s ODSE rules and guidance now provides sufficient clarity to understand, in considerable detail, how the landscape for club hierarchies is set to change. 

A broader scope than previous tests 

Similar personnel tests have existed previously under league and FA rules. However, the IFR-led regime differs both in scope and intensity.

Most notably, the ODSE Regime extends beyond owners and directors to include senior executives. The original Owners’ and Directors’ Test (introduced in 2003 and later referred to as the Fit and Proper Persons Test) applied only to owners and directors. The new regime moves further down the organisational structure to capture individuals who perform a “senior management function” or who manage one or more significant aspects of a club’s affairs.

The specified senior management functions are: 

• Chair function 
• Chief Executive function 
• Chief Finance function 
• Chief Operations function 
• Director function
• Other Key Decision Maker function 

The inclusion of an “Other Key Decision Maker” function is deliberately broad, and may capture individuals who exercise material influence even where they do not hold a formal title. This means that a very wide range of potential applications are now being brought under a single regulatory umbrella. Given this diversity, the IFR may face challenges in implementing a ‘one size fits all’ approach to the ODSE regime.

Clubs should therefore not assume that existing job titles automatically determine whether an individual (or a particular role) is in scope. Careful consideration of governance structures and decision-making authority will be required.

Notification and timing considerations 

The IFR has indicated that it expects to receive notice of an appointment when there is a “reasonable prospect” of that appointment taking place, or when a single preferred candidate has been identified.

In practice, this creates potential timing challenges. Clubs may reach an advanced stage of recruitment before regulatory engagement is complete. If a candidate were subsequently to fail the tests, this could give rise to operational disruption and reputational difficulty. This is particularly noteworthy as the IFR has up to 90 days, extendable to 150 where necessary, to make a judgement on any new appointments.

While the expectation is that for routine appointments the approval process will be much faster than these regulatory limits, given that the process of approval may take up to five months clubs may wish to attempt to seek regulatory clearance at an earlier stage in recruitment processes than the IFR guidance currently suggests.

With the regime expected to become operational from 5 May 2026, clubs currently contemplating senior appointments should be assessing now how the new requirements will interact with their recruitment timelines.

A statutory and more intrusive regime 

The ODSE Regime also differs from its predecessors insofar that it is underpinned by statute.

This gives the IFR powers to compel information from prospective and incumbent owners, directors and senior executives. This differs from the existing Owners and Directors’ Tests implemented by league bodies, which are a matter of contract between the clubs and the leagues. The key difference between the two models is that, given the contract-based nature of tests under the leagues, clubs have ultimate control over the regime – this will not be the case with IFR’s ODSE stipulations.

The information required under the ODSE Regime is furthermore more detailed and rigorous than under earlier iterations. Individuals classified as Directors or Senior Executives will be required to meet minimum standards across three core pillars: 

1. Honesty and Integrity
2. Financial Soundness
3. Competence 

Each pillar contains a series of granular requirements. These include: 

1. Disclosure of any sanction received from a sporting competition organiser
2. Whether the individual has misled a regulator
3. Any Debt Relief Order or Individual Voluntary Arrangement (as part of a wider financial assessment)
4. Evidence of the necessary skills and experience for the role
5. Financial details of entities in which the individual has held a controlling interest, significant influence or position of responsibility 

Owners will be subject to these same criteria (other than competence), alongside additional tests relating to financial resources and sources of wealth, including scrutiny of any links to serious criminal conduct. 

The more granular nature of the new ODSE regime is highlighted by the inclusion of skills and experience to form part of the competence test. This is a significant level of new detail which has not previously been administered, with individuals having to undergo screening on core competencies, in addition to general background.

Incumbents and the licensing process 

The ODSE Regime also has the capacity to examine incumbent owners, directors and senior executives, not solely prospective appointees. Although the IFR has indicated that it does not intend to conduct a wholesale retrospective review, it retains the power to investigate existing individuals where concerns arise. 

In addition, clubs will be required to submit a Personnel Statement identifying all senior management and above as part of their Provisional Operating Licence application. This licensing process is due to commence in Autumn 2026.

Taken together, these developments represent a substantive increase in the regulatory scrutiny applied to club leadership. 

The need for early preparation 

Whilst the objectives of the ODSE Regime are welcome, the regime represents a significant increase in stringency.

The immediate priority for clubs is awareness. From 5 May 2026, many new senior appointments will fall within the regime’s operational scope. As a result, governance structures may require reassessment, and recruitment processes may need adjustment to accommodate regulatory engagement.

Clubs that consider these issues now — before making senior appointments — are likely to experience a smoother transition than those that defer engagement until a regulatory trigger arises.

How LCP can support clubs 

Given LCP’s experience of navigating complex regulatory environments across multiple sectors, we are launching a dedicated service within LCP Assist to support clubs in managing the ODSE Regime. Our support covers four key areas:

1. Scoping – Interpreting detailed regulatory definitions to identify which individuals and roles fall within scope.
2. Notifying – Assessing whether any current or anticipated personnel changes require notification to the IFR.
3. Assessment – Conducting preliminary reviews of prospective owners, directors and senior executives to identify potential areas of regulatory concern.
4. Presentation – Assisting with the preparation of documentation required by the IFR under the ODSE Regime.

Overall, the ODSE Regime represents a firmer and more expansive framework than those which preceded it. With operational engagement commencing in May 2026, clubs should now be considering how they will address the new requirements. Early and structured preparation will be central to ensuring regulatory compliance and operational continuity under the new regime.