Independent Football Regulator’s ODSE Regime marks major shift in club Governance from May and Clubs need to be aware – LCP

LCP are urging clubs to factor in new rules from the Independent Football Regulator (IFR) that will mean that senior recruitment will require regulatory engagement and approval.

In a new blog, LCP has outlined the impact that the IFR’s Owners, Directors and Senior Executives Regime (ODSE) will have when it is extended into a new framework covering new owners and appointments of directors and senior executives from 5th May. This follows on from the publication by the IFR of new rules and guidance for the ODSE, and means that football clubs across the top five tiers of the men’s game will face a significant change in regulatory scrutiny.  

The ODSE Regime, elements of which came into force in December last year, introduces a broader and more rigorous framework for the vetting and monitoring of club leadership.  

Under the new rules, clubs will be required to engage with the IFR when making many senior appointments, with regulatory approval needed before individuals can take up their roles. In addition, clubs will be required to identify all senior management as part of their Provisional Operating Licence applications, due to begin in Autumn 2026, further increasing the level of scrutiny applied to club hierarchies. 

Key things that clubs need to consider are:  

• Most notably, the ODSE Regime extends beyond owners and directors to include Senior Executives. Clubs shouldn’t 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.  
• 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. 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. 
• The ODSE Regime also differs from its predecessors because it is underpinned by statute, which makes it a more intrusive regime. 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.
• 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.