LCP and LawDeb urge more pragmatism and clarity in the football regulator’s internal review process
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In response to the Independent Football Regulator’s (IFR) consultation on its proposed Internal Review Function, LCP and The Law Debenture Corporation plc (LawDeb) have submitted a joint response calling for greater pragmatism and clarity in how the new regulator handles appeals and challenges to its decisions.
The IFR, established earlier this year under the Football Governance Act, is tasked with overseeing financial sustainability and governance across English men’s football. The internal review process will be a key mechanism for ensuring accountability in the regulator’s decision-making.
LCP and LawDeb welcome the rigour of the proposed internal review process but have raised concerns about the practical implementation of the internal review framework. Their recommendations include:
- Clearer criteria for identifying “concerned persons” eligible to request reviews, to avoid ambiguity and potential legal challenges.
- More flexibility around the seven-day deadline for submitting review requests, which may be too short for clubs or individuals to seek legal advice.
- Publication of internal review decisions and reasoning, to promote accountability and build public trust.
- A full public review of the internal review function after the first 12 months, to assess its effectiveness and identify areas for improvement.
- Disclosure of indicative costs for internal reviews, to ensure transparency and avoid unexpected financial burdens on clubs.
The IFR has an opportunity to set a new standard for regulatory fairness and improve the financial sustainability and governance of men’s football. But to do so, it needs to be transparent, pragmatic and responsive to the realities clubs face. Incorporating our recommendations to the internal review process will help make the process fairer and boost accountability.
Aaryaman Banerji Head of Football Governance at LCP
LCP and LawDeb’s recently published a joint report, Football Governance in Transition, which analysed the board composition of 116 regulated clubs and called for reforms to improve board diversity, director competence, and minimum governance standards.
